Comments on Straw proposal and 8/11 meeting

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

While ACP-California would support targeted modifications in certain areas that were addressed in Section 2 of the IPE 5.0 Straw Proposal, as discussed more below, we feel that it is more important for CAISO to focus on other, more pressing modifications, such as: changes to the timelines for signing Generator Interconnection Agreement (GIAs), the treatment of Long Lead-Time (LLT) resources, and the treatment of Energy Only (EO) resources. Nevertheless, ACP-California appreciates CAISO seeking feedback from local regulatory authorities on the LSE allocation process (Section 2.1) and looks forward to reviewing any LRA feedback that is received. 

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

Section 3.1 Allowing operational Energy Only projects to seek deliverability:

ACP-California strongly supports CAISO reconsidering including this item in IPE 5.0. We would support, at a minimum, CAISO incorporating the CalCCA proposal which would allow operational EO projects in C15+ to seek deliverability by re-entering the interconnection queue, which could offer a pathway to addressing future situations where there is an RA need for California LSEs.

ACP-California has previously noted that this policy (of not allowing EO resources in C15 to ever secure deliverability), while approved, was not well documented or discussed through the IPE 2023 stakeholder process and first appeared in the CAISO’s IPE 2023 Track 2 Final Proposal Addendum. We understand and appreciate CAISO’s interest in ensuring that projects don’t undermine the interconnection queue through an EO request. However, CAISO has declined to further consider the most reasonable and cautious approaches, including those put forward by CalCCA and other stakeholders. ACP-California strongly supports CAISO creating (at minimum) an opportunity for operational EO projects in C15+ to seek a deliverability allocation through re-entering the queue and seeking deliverability. While the number of projects that might be expected to come online as EO and seek a TPD allocation in C15 and future clusters is expected to be small, CAISO can mitigate concerns about significantly disrupting the queue process by enacting CalCCA’s proposal to allow these resources to “re-enter” the queue to seek a TPD allocation once they are operational.

CAISO’s reliance on “queue data” as a reason to not take up any form of reasonable modification to the treatment of EO resources in C15 and beyond is not rational. While CAISO declines to take this up due to, in part, C15 data suggesting that the proportion of EO is in line with past CPUC portfolios, the evolution of the CPUC’s RA program to include energy sufficiency requirements which must be met with deliverable resources will necessitate a revised approach in future portfolio development. Additionally, as ACP-California has identified within the CPUC RA and IRP proceedings, the current IRP analytical framework approaches EO resources inconsistently to RA requirements with respect to energy sufficiency requirements – within the RESOLVE and SERVM frameworks, EO resources are available to provide off-peak energy sufficiency for storage charging, supporting their selection in lieu of deliverable resources and failing to identify corresponding deliverability upgrade needs within the TPP. While ACP-California looks forward to continued collaboration with the CAISO and CPUC to align these programs and expand pathways which recognize the important reliability potential of EO resources, deliverability remains paramount for resource viability and full participation in CAISO and CPUC RA programs. On this issue, legacy IRP portfolios are a poor guide regarding forward-looking needs. And CAISO should support options for increasing resource deliverability to maintain flexibility to meet the large amount of expected future resource needs.

ACP-California has also previously commented (in the IPE 2023 initiative) on the “problem the ISO would be solving” by providing a pathway to deliverability to EO resources in Cluster 15+. In considering the problem that would be addressed by providing a pathway to deliverability for online EO projects, CAISO should consider the problems that would exist if, in the future a C15+ project that is online is not allowed to seek a TPD allocation. Imagine a situation where there is an EO project that has achieved commercial operation and there is a tight market for RA. And, in this example, assume that the existing, online EO project could contribute additional capacity to the RA market, if it could just secure a TPD allocation. Under the current rules, CAISO would not allow this resource to compete for a deliverability allocation at all. And yet, a different project early in the development cycle, could apply to enter the queue and secure the same deliverability. But it would take many years (along with additional, potentially higher development costs) for that other project to achieve commercial operation and actually be able to contribute to the RA requirements of LSEs. And during those years, the EO project would be available (and could have been contributing to RA requirements of LSEs). Thus, in this hypothetical example, as a result of CAISO’s policy, the RA market would be shorter than it needed to be (and than it would have been if the online, EO project could have sought a deliverability allocation). If this delay in securing additional RA resources results in an LSE being short on its RA requirements, there could also be penalties that would apply to the LSE.

Finally, statements made by CAISO staff in the workshop that EO projects do not need deliverability to be economically viable ignores the changing landscape of the energy and capacity markets. Economic assumptions made by EO projects may change over the course of a project’s life, making deliverability necessary to continue the project’s economic operation.

All-in-all, the policy of never permitting EO resources to seek deliverability only serves to potentially increase costs for meeting RA needs and is not a reasonable approach. Instead, the CAISO should allow EO projects to compete for deliverability through the Commercial Operation group for Cluster 15 and beyond. We urge CAISO to revisit this item and include a proposed policy modification in the next proposal of IPE 5.0. If the CAISO has concerns about interconnection customers attempting to use the EO pathway to “game” the system if there are later opportunities to receive deliverability, it should be explicit with what those concerns are and how, if customers are required to reenter the queue, they would retain an unfair advantage within the process.

Section 3.2 Consideration of allowing long lead-time resources to defer seeking deliverability

In IPE 2023, CAISO spent significant time with stakeholders discussing the unique position of LLT resources and the need for these resources to have a modified process for securing TPD. CAISO previously proposed a highly workable solution where designated LLT resources would be able to enter the queue and defer their first opportunity to seek TPD to more closely align with their project development and procurement timelines. ACP-California appreciates CAISO’s prior thoughtful and proactive efforts to date on this topic and was disappointed that this item was not included in the final IPE 2023 Track 3 proposal and is not proposed to move forward in IPE 5.0.

ACP-California encourages CAISO to further consider this topic in IPE 5.0, as there continues to be a need to explore the unique position of LLT resources in the new interconnection process and ensure that they are appropriately situated to receive a deliverability allocation on a timeline that aligns with procurement efforts, many of which will likely be through the Department of Water Resources (DWR) central procurement process. The timelines for central procurement are uncertain and may shift as the process evolves. For certain long-lead time resources, such as offshore wind, central procurement offers the only viable opportunity to secure a PPA for the entirety of a project in alignment with the capacity of that project’s interconnection request. Thus, it is imperative that CAISO has a process for allocating deliverability to these resources that includes appropriate flexibility to recognize this unique set of circumstances.

Further, as the CAISO intends to continue to reserve deliverability for LLT resources through the process articulated in IPE 2023 and recently approved by FERC, we believe it would be advantageous for the CAISO to have earlier awareness of the scale, location, and timelines of projects eligible to receive that deliverability in the future, as provided in a project’s interconnection request. If a LLT resource developer has to wait to enter the queue until they are at maximum three years-out from securing a PPA, the CAISO will have less insight into the progress and needs of these projects and the associated effects on the system plans and needs.

While we understand there has not been unanimous stakeholder support for this item, we hope to be able to continue discussions on appropriate treatment of LLT resources in C15+ to meet the state’s policy objectives through IPE 5.0. Moreover, to the extent CAISO continues to propose not to take this issue up in IPE 5.0, ACP-California would appreciate CAISO articulating how the current process could appropriately accommodate LLT resource deliverability allocation given the unique procurement and development timelines of these resources.

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

ACP-California continues to support ongoing discussions on items raised by stakeholders including addressing the misalignment between the long development timelines for network upgrades and the resource development process (Section 4.1), but offers more specific comments on the following sections of the Straw Proposal.

Section 4.2 Adjust required generator interconnection agreement (GIA) execution to be after all deliverability allocations are complete

In the last round of comments, LSA and Invenergy highlighted the disconnect between the FERC Order 2023 timeline for execution of GIAs and the CAISO’s deliverability allocation process. Notably, the current processes could require generators to sign GIAs before knowing whether they have been allocated deliverability or not. In the Straw Proposal, CAISO declined to further consider modifications to address this disconnect. However, this is an area the CAISO should take up in future versions of the IPE 5.0 proposals, as failing to address this disconnect will result in significantly (and unnecessary) churn and create a new set of questions and issues that will need to be addressed. CAISO can avoid these undesirable outcomes by simply proposing a modification to the GIA signing timelines that were a part of Order 2023.

First, CAISO should feel empowered to proposed modifications to the FERC Order 2023 requirements/timelines, as FERC has accepted a variety of deviations and, in particular, is more likely to accept deviations from the Order 2023 requirements from an independent entity like CAISO. Additionally, CAISO is likely to have significant stakeholder support for modifying the Order 2023 timeline for GIA execution to better align with CAISO’s unique TPD allocation timelines. And CAISO can point to the benefits that would be achieved through a deviation to the Order 2023 timelines in this unique circumstance.

Additionally, CAISO should consider the administrative and process burden that will occur if more generators sign GIAs than will ultimately connect to the system. CAISO’s interconnection queue processing allows capacity of 150% of the available deliverability to enter the interconnection queue. If all of these resources choose to sign GIAs, even when they don’t know if they will get deliverability or not, it will create additional administrative burden for generators, the PTOs, and CAISO. This is especially true because many of these projects may ultimately not proceed into operations and will need to terminate their GIAs at some point in the future if they do not receive a TPD allocation.

And, as was discussed during the stakeholder call, CAISO should also consider what happens under this policy if a generator signs a GIA, does not receive a TPD allocation, but proceeds to commercial operation under the GIA anyway. It is appropriate to consider how the CAISO would address this situation and whether the project would be Energy Only, whether (because it entered the queue as deliverable) it would be eligible for a subsequent TPD allocation, etc.

While it may be possible to answer these questions, ACP-California – instead – strongly supports CAISO addressing the underlying issue and proposing modifications to the Order 2023 timelines within CAISO such that projects are not required to sign a GIA before knowing whether they have deliverability or not. This will reduce administrative churn and the need to answer the policy questions discussed above.

Section 4.4 Explore process changes to align with near-term procurement discussions

ACP-California appreciates the CAISO’s commitment to linking the interconnection process to procurement discussions. And, to the extent there is future procurement activity that warrants additional discussions on this topic, ACP-California looks forward to working with the CAISO to consider whether modifications are necessary to CAISO’s processes/timelines to allow for timely interconnection of resources for near-term needs. To the extent these discussions become necessary and appropriate, ACP-California would encourage CAISO to think broadly and be open to a variety of different approaches to facilitating more near-term operation of resources in the queue, including being open to modifications to the treatment of EO resources in the queue (potentially allowing them an opportunity to seek deliverability in more than the commercial operation group).

Specifically, CAISO should consider continuing to allow pre-C15 EO projects to seek deliverability in the PPA or Shortlist groups, similar to the allowance in past TPD cycles.  For similar reasons outlined in the response to Question 2, CAISO should be open to pathways for projects that have shorter timelines for providing needed resource adequacy to receive deliverability. Some pre-C15 projects may have become EO due either to past development challenges or material modifications, but now that they have a commercial path forward demonstrated by a PPA or shortlist, they should be given an additional opportunity for deliverability. These may be projects that were never predicated on economic viability solely from EO operation and thus would not continue to be developed if a pathway to deliverability is not viable. The TPD scoring and ranking approach already gives preference to projects that entered the queue seeking deliverability, so deliverable projects pre-C15 will not be harmed by creating additional opportunities for pre-C15 projects to convert to FCDS. And while it is possible that providing opportunities for pre-C15 EO projects to obtain deliverability in the PPA or shortlist group could utilize deliverability that might otherwise be available for C15, the projects in C14 (and earlier) have a better chance of coming online earlier and helping meet near-term system needs.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

No comments at this time.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

No comments at this time.

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

No comments at this time.

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

AES COMMENTS ON INTERCONNECTION PROCESS ENHANCEMENTS 5.0 STRAW PROPOSAL

AES appreciates this opportunity to comment on CAISO’s August 4th document, Interconnection Process Enhancements 5.0 Straw Proposal (Proposal). AES's comments are formatted to follow the topics in the Proposal:

• IPE 2023 Track 2 CAISO commitments to monitor and revisit C15 Interconnection Request intake elements
• IPE Track 3 CAISO commitments to "revisit policy ideas"
  Additional stakeholder suggestions for IPE 5.0
• Additional CAISO-proposed issues for IPE 5.0

IPE 2023 Track 2 Commitments

Transparency, rigor, and integrity of the LSE allocation process

CAISO Proposal: No changes proposed or suggested; seeking feedback from local regulatory authorities on transparency, rigor, and integrity of the LSE allocation process.

AES Comments: While we recognize that local regulatory authorities have primary oversight of LSE allocation processes, AES has concerns about the compressed timeline and limited engagement opportunities observed during the Cluster 15 LSE allocation process. Some LSEs have imposed fees and advance concessions that may not align with actual procurement needs, creating barriers for certain developers. AES supports increased oversight and transparency measures, including clear timelines for LSE point allocation decisions, standardized criteria that align with procurement obligations rather than developer payments, and regular reporting on allocation patterns to ensure alignment with actual procurement needs.

Cap on full allocation election

CAISO Proposal: The ISO recognizes small LSE concerns about insufficient points and will consider proposals to modify this allocation, but suggests that stakeholders propose solutions that adhere to the fundamentals of the approved full allocation election cap.

AES Comments: AES recognizes the concerns raised by smaller LSEs regarding insufficient points for resource replacement needs. We support stakeholder-proposed modifications that maintain the fundamental principles while providing additional flexibility for legitimate resource replacement scenarios, particularly where retiring resources are larger than individual LSE CI point allocations.

Methodology for award of commercial interest points based on POI capacity

CAISO Proposal: The ISO determined the current FERC-approved policy is sound and does not propose any changes after finding no evidence that the current process resulted in adverse outcomes.

AES Comments: AES has concerns about the current methodology's treatment of hybrid projects seeking partial deliverability. The requirement to secure CI points for the entire POI capacity when only a portion seeks Full Capacity Deliverability Status (FCDS) creates an inequitable scoring disadvantage for hybrid configurations. For example, a 100MW project with 50MW FCDS storage and 50MW Energy Only solar should only require 50MW of FCDS CI points for the storage portion, with the solar assessed separately. This would provide much more Resource Adequacy value than a 100MW Energy Only project yet requires the same CI point allocation under current rules. AES supports allowing projects to split CI point requirements between FCDS and Energy Only portions to promote more efficient hybrid project development while maintaining scoring integrity.

Incorporation of WDAT projects into intake scoring

CAISO Proposal: Require any distributed projects seeking deliverability to participate in cluster deliverability studies by submitting intake scores through the same application window, with ISO and UDC validation of project eligibility. Distributed resources that already have deliverability or are being studied will not be affected.

AES Comments: AES supports the principle of equal treatment for all projects seeking deliverability, regardless of interconnection level. We request that CAISO provide detailed analysis of the capacity impact and ensure that the 150% study limits are appropriately adjusted to account for distributed project participation without disadvantaging transmission-connected projects.

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

Allowing operational Energy Only projects to seek deliverability

CAISO Proposal: The ISO does not propose changes because the queue data do not support the need to reopen this pathway. The ISO requests that stakeholders articulate what problem this would solve so the ISO can weigh benefits and risks.

AES Comments: AES does not support creating a pathway for operational Energy Only projects to seek deliverability through the standard interconnection request process. Such projects have already proven their commercial viability in an energy-only configuration.

Consideration of allowing long lead-time resources to defer seeking deliverability

CAISO Proposal: The ISO does not propose allowing long lead-time resources to defer their first attempt to seek deliverability due to insufficient stakeholder support and potential delays to other projects and network upgrade construction.

AES Comments: While we understand CAISO's position, AES believes this issue warrants reconsideration given the commercial challenges faced by long lead-time projects under current timelines. Earlier PPA contracting processes, such as those being developed in the CPUC's RCPPP proceeding, could address timing misalignments without requiring special interconnection rules.

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

Address timing issues for projects with long lead-time DNUs

CAISO Proposal: The ISO does not propose additional reform to the deliverability allocation process. Track 3 addressed the deliverability allocation process, and the ISO does not believe further changes are warranted at this time. The ISO may revisit this issue after Track 3 reforms have been implemented in 2026.

AES Comments: This is a critical issue for AES's project development timeline. Projects that could reach commercial operation significantly before required transmission upgrades create commercial uncertainty that hampers PPA negotiations and project financing. Despite CAISO's reluctance to pursue changes at this time, AES strongly supports proposals similar to Clearway's framework that would allow projects to receive multi-year interim deliverability before transmission upgrades are completed. This would provide commercial certainty and enable earlier project monetization, helping projects achieve commercial operations years before network upgrades are complete. We urge CAISO to reconsider this position and prioritize this issue given its importance to project viability and the ability to accelerate clean energy deployment.

Adjust LGIA execution timing relative to TPD allocation

CAISO Proposal: The ISO proposes to retain the existing FERC Order 2023 timeline for GIA execution, requiring interconnection customers to execute GIAs and post deposits understanding the risk that they may not ultimately receive deliverability.

AES Comments: Despite CAISO's proposal to maintain current timelines, AES has concerns about requiring GIA execution and deposit posting before projects know their deliverability status. This creates significant financial risk for projects that may ultimately be removed from the queue after failing to secure deliverability over three attempts. We support modifications that would defer GIA execution requirements until after the first TPD allocation results, at least for projects that do not receive allocations on their first attempt, to avoid wasteful commitment of PTO and developer resources to potentially non-viable projects.

Provide consolidated and searchable network upgrade data

CAISO Proposal: The ISO is working to improve data availability throughout the interconnection process and is considering stakeholder requests to share updated POI information at key milestones. The ISO does not view this as requiring tariff changes.

AES Comments: Enhanced data transparency is critical for informed project siting and reducing speculative queue entries. AES supports early release of substation-level feasibility data, known constraints, and TPD mapping information, particularly given Order 2023 site control requirements. We request that CAISO provide preliminary C16 information shortly after March 2026 TPD allocation results, with final information available by June 2026 following Transmission Plan approval.

Commercial readiness deposit due date

CAISO Proposal: The ISO proposes that commercial readiness deposits will only be required for projects that have successfully completed the scoring and ranking steps and are proceeding to interconnection request validation, with deposits due by the close of the Customer Engagement Window.

AES Comments: AES supports this modification as it addresses practical coordination challenges between developers and PTOs while maintaining project viability screening. This change provides more manageable timing while preserving the intent of the commercial readiness requirement.

Discontinue pre-application process

CAISO Proposal: The ISO proposes to remove Section 1.3 Pre-Application from ISO Tariff Appendix KK, noting the process is rarely used appropriately and provides potentially misleading information while consuming valuable resources.

AES Comments: AES supports discontinuing the pre-application process. Given improved data availability through other channels, this process provides limited value and current data availability makes it largely redundant.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

AES appreciates CAISO's measured approach to IPE 5.0. While we understand CAISO's reluctance to make significant changes to recently implemented reforms, we believe several targeted modifications would significantly improve project development efficiency without undermining the fundamental improvements achieved in recent reforms.

We particularly encourage CAISO to reconsider its positions on long lead-time DNU timing relief and hybrid project CI point methodology improvements, as these issues create significant commercial barriers for viable projects that could otherwise contribute to California's clean energy goals more efficiently.

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

The California Community Choice Association (CalCCA) appreciates the opportunity to comment on the California independent System Operator’s (CAISO) Interconnection Process Enhancements (IPE) 5.0 Straw Proposal.

Proposal 2.1

CalCCA agrees with the CAISO that no changes to the load-serving entity (LSE) commercial interest point allocation process are needed at this time. To facilitate LSE review of interconnection requests eligible for scoring in future clusters, CalCCA requests that the CAISO provide LSEs with a complete list of interconnection requests immediately after the close of the interconnection request window. While LSEs had access to such a list in Cluster 15, that was a unique circumstance, and a consistent process should be established going forward.

Additionally, the timeline for LSE scoring should be extended from ten days to three weeks (21 calendar days) following the close of the interconnection request window. This adjustment will allow LSEs sufficient time to review the full set of eligible projects and ensure their scoring decisions are well-informed. Understanding the full set of potentially eligible projects not only helps ensure accuracy in scoring submittals, but also enables LSEs to weigh trade-offs and make more strategic decisions on which projects best align with their future procurement needs.

Proposal 2.7

CalCCA does not oppose the CAISO’s proposal to require any distributed projects seeking to participate in the CAISO markets with deliverability to take part in a cluster deliverability study, with the clarification that LSEs would be able to allocate commercial interest points to Wholesale Distribution Access Tariff (WDAT) projects. This clarification is necessary so these projects can be scored comparably with other resources given the projects’ deliverable capacity would contribute towards the 150 percent capacity limit for its point of delivery to the CAISO controlled grid. In addition, the CAISO should clarify whether it plans to add additional transmission plan deliverability capacity to the commercial interest scoring process if these projects are part of the 150 percent capacity limit.

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

CalCCA appreciates the CAISO including in the scope of this initiative “Allowing Operational Energy Only [EO] Projects to Seek Deliverability.” While the CAISO does not propose changes at this time, the CAISO asks stakeholders who support a pathway for EO projects to obtain deliverability to “articulate the problem the ISO would be solving.”[1] This pathway would address the following problems:

• While there may be many projects seeking deliverability in the queue, LSEs are not experiencing an over-abundance of viable deliverable resources with which to contract. When LSEs evaluate offers, they may not contract with projects for various reasons, such as prices offered, development risk (e.g., permitting), portfolio mismatch, or other reasons. CalCCA members have expressed interest in procuring a diverse set of resources like wind, long-duration storage, and geothermal, but many receive very few, if any, cost-effective, viable offers.[2] EO wind resources could offer an opportunity to increase resource diversity in a cost-effective manner in the event there is insufficient supply from projects that sought the deliverable pathway from the outset.  
• Procurement orders from the California Public Utilities Commission (CPUC) historically require all capacity to be deliverable.[3] LSEs face penalties based on the net cost of new entry (CONE) when they do not bring sufficient deliverable capacity online by the deadlines of the procurement orders, which can contribute to increased ratepayer costs. The CPUC is developing a Reliable and Clean Power Procurement Program (RCPPP) that will establish mid to long-term procurement obligations for LSEs on a regular basis. CalCCA expects LSEs will be required to procure deliverable capacity for their RCPPP procurement obligations and face penalties for non-compliance. If the supply of deliverable capacity is constrained, EO projects seeking deliverability could provide a timelier and more affordable pathway to meeting compliance obligations. While EO projects are included in the CPUC portfolios, it is critically important that the system has the amount of deliverable capacity it needs to support reliability. If EO only projects can provide a timely and cost-effective pathway for developing additional deliverable capacity needed to meet procurement requirements, this pathway should be an option to support reliability and affordability objectives.
• Resource Adequacy (RA) capacity has been scarce for a few years. While recent build has helped, load growth may account for all of the recently built capacity, requiring more RA to be procured. CalCCA’s most recent analysis of the RA stack suggests that tight market conditions (RA surplus of 2000 megawatts or less) could return as soon as 2029. Given a choice between pursuing uncertain imports for RA, building a new resource, or contracting with an existing EO resource to provide incentive to pursue network upgrades to become deliverable, more competition for providing RA will benefit consumers in reaching their reliability goals affordably. In fact, it may be that converting an EO facility to fully deliverable may be the quickest, most certain, and most cost-effective way to meet RA needs since the resource is already in California, is operational, and has an EO contract to address all costs except the costs of network upgrades. 
• Some projects can only be financed as EO but could provide additional reliability value later on if they have a pathway to obtain deliverability. For example, one CalCCA member explained that it obtained grant funding for a project but only if the project reached COD by a certain date. This date was feasible only if the project used the EO pathway. If projects in Cluster 15 or forward experience similar situations, these projects should be able to enter the queue as EO, to allow new projects to be developed in a more timely and cost-effective manner, and later seek deliverability if reliability needs that the project could support are identified. As a result of HR1,[4] projects must begin construction by July 4, 2026, and be placed in service by December 31, 2027, to obtain ITC and PTC. With a projected October 1^st, 2026, Cluster 16 window, as well as the time needed to complete scoring, studies, and needed grid upgrades, it is not realistic for any full capacity deliverability status (FCDS) projects not yet in the queue to qualify for these tax credits. However, an EO distribution level project may reach its commercial operations date (COD) in time to qualify. This pathway may both improve project economics and expedite the interconnection of deliverable capacity to support urgent reliability needs, as was done to address emergency reliability needs in 2021.[5] CalCCA is aware of multiple projects that would benefit from this pathway as a way to secure ITC and PTC tax credits. Without an online-EO to FCDS pathway, California cannot capture these significant developer, LSE, and customer savings.
• The CAISO should expect that the balance of fully deliverable requests for interconnection versus energy only will change over time. The deliverability need is a function of RA and Integrated Resource Plan needs.  If those processes produce an excess of fully deliverable capacity, the most cost-effective manner to meet Renewables Portfolio Standard may be to procure energy only projects which could increase the number of resources interconnecting as energy only. However, if the need swings back to demand for RA fully deliverable resources, the most cost-effective solution may be to restudy an energy only project to perform deliverability upgrades to satisfy the RA need.  Prohibiting energy only resources from ever seeking deliverability once interconnected will not produce the most cost-effective solution and should be reconsidered. 

The CAISO should therefore adopt CalCCA’s proposal as stated in the Straw Proposal.[6] CalCCA’s proposal would require the EO project to re-enter the queue for study under the full set of existing CAISO criteria, demonstrate a power purchase agreement for RA capacity to obtain deliverability, and to be limited in the number of times it can re-enter the queue. This proposal addresses the CAISO’s concerns of projects circumventing the competitive queue process for deliverability and congesting the queue – concerns CalCCA shares. The CAISO and stakeholders have not yet identified any major issues with this proposal that would prevent its adoption.

[1]            Id., at 14.

[2]            CalCCA recently surveyed its members about its procurement efforts for non-solar/storage capacity. Twelve CCAs responded, representing over five million customers and 205 terawatt hours of energy sales annually. When asked if the CCA had selected any non-solar and non-storage resources in recent (i.e., in the last five years) RFOs, a very small fraction said that they had done so with a resource priced at or below net CONE. Instead, most were procured at costs above net CONE and most of those were the result of meeting mid-term reliability (MTR) requirements for long-lead time resources or baseload non-emitting resources. CalCCA asked if the CCAs had declined offers from non-solar/non-storage resources over that same time frame. Most entities indicated that there were no or very few offers that they declined. In addition to those CCAs, one indicated that it received a reasonable number of offers but like other CCAs, it declined the offers as they were above the net CONE value and not economic compared to other alternatives to fill their portfolio needs.

[3]            Decision 21-06-035, Decision Requiring Procurement to Address Mid-Term Reliability (2023-2026), Rulemaking 20-05-003 (June 24, 2021): https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M389/K603/389603637.PDF.

[4]            OBBBA, H.R. 1 (July 4, 2025) (modifying energy tax provisions in the Inflation Reduction Act of 2022 (the IRA), and accelerating the phaseout of the technology-neutral tax credits, Section 45U Clean Electricity Production Tax Credit (PTC) and Section 48E Clean Electricity Investment Tax Credit (ITC)).

[5]            Resolution E-5183. Southern California Edison Request for Approval of Emergency Reliability Engineering, Procurement, Construction, and Maintenance Contract for Utility-Owned Storage Resources (Dec. 16, 2021): https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M432/K713/432713159.PDF (approving Southern California Edison Company’s emergency reliability procurement of utility-owned storage that will initially operate as a distribution asset and later transition to participate in the wholesale market by submitting an interconnection request to do so pursuant to the WDAT and proceeding through the interconnection process like any other interconnection customer).

[6]            Straw Proposal, at 13-14.

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

CalCCA has no comments on Section 4 at this time.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

CalCCA has no comments on Section 5 at this time.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

CalCCA agrees that this initiative falls within the Board of Governors purview only.

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

CalCCA has no additional comments at this time.

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

 No comment.

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

Comments on 3.1. - Allowing operational Energy Only projects to seek deliverability

CalWEA supports CalCCA’s proposal that projects that have achieved commercial operation as Energy Only (EO) should be allowed to submit new interconnection requests, apply for deliverability allocation, and be scored along with all other projects seeking deliverability with the same network funding obligations. This is consistent with MISO and PJM practice. CAISO requested, in the Straw Proposal, that stakeholders “articulate the problem the ISO would be solving, so the ISO can weigh the benefits and risks of such a pathway.” 

Allowing operational EO projects to re-enter the queue addresses the barrier that, post-C14, projects that entered the queue as EO because deliverability at their point-of-interconnect was not available at that time are forced to remain EO forever. This is true even if new transmission upgrades that provide TPD capacity in their study area are planned and these projects have proven their viability by having secured financing and having been built as EO projects. Such projects, if granted deliverability, would bring the benefits of contributing RA to the market and meeting system RA needs sooner than early-stage projects could. Forcing operational EO projects to remain forever as EO – or, worse, discouraging such projects from ever materializing by denying them the prospect of attaining deliverability status – is patently unfair because these projects provide reliability benefits but are not compensated for them. The current CAISO policy also withholds RA capacity from the market, which raises consumer costs.  

Indeed, by virtue of having proven their viability and being able to contribute immediately to system reliability, operational EO projects should receive priority in TPD allocations. CalWEA is not aware that the CPUC has requested CAISO to enforce a constraint that EO resources should remain EO indefinitely as modeled in RESOLVE, rather than allowing Load Serving Entities to bilaterally procure the mix of resources that fits their CPUC-jurisdictional Slice of Day obligation. This administrative restriction is at odds with the “Open Access” philosophy of RTO/ISOs. The problem that the CalCCA proposal seeks to resolve is that even a thorough and well-coordinated transmission planning and generation procurement process is at risk of under-forecasting system need or imperfectly aligning in-service dates, and the IPE Track 2 policy is cutting off the most efficient pathway for market participants to address these imbalances.

Although FERC approved the IPE Track 2 reforms as just and reasonable, that approval does not mean that all other outcomes are unjust and unreasonable. At the September 10, 2024, FERC technical conference on Innovations and Efficiencies in Generator Interconnection, interim EO service before conversion to full deliverability was among the suggested efficiencies.[1]

At a minimum, operational EO projects should be able to enter the TPD allocation process to receive unallocated TPD capacity.

The Straw Proposal notes that, in the past, EO projects “tended to linger in queue.”  This is highly unlikely to occur if CalCCA’s proposal is adopted because projects that become operational will have met a very high bar that “lingering” EO projects did not have to meet.  Further, CalCCA added provisions to the proposal to ensure that the policy is not over-utilized.[2] CAISO staff confirmed that, in the past, only one resource has been converted to FCDS after reaching COD as an EO project, so it is unclear why CAISO believes an unmanageable number of resources will take advantage of this provision. Enforcing appropriate CVC demonstrations should resolve concerns about EO resources “lingering.”

CAISO suggested that cluster 15 includes enough EO projects to fulfill the need for EO projects reflected in the CPUC’s portfolio.  However, there is no assurance that these EO projects will be sufficiently commercially viable to be built. Providing a pathway to FCDS will encourage developers to begin development with EO status. At the CPUC busbar mapping methodology kickoff call last week, the CPUC sought comment on appropriate data sources for areas of interest now that CAISO queue data cannot be used as an input for where generation resources can develop. Allowing EO resources to be studied for deliverability upon COD would maintain the interconnection queue as a viable input data source to indicate POIs of interest for future transmission upgrades.

3.2. Consideration of allowing long lead-time resources to defer seeking deliverability

CalWEA supports ACP-California and Invenergy’s proposal to allow long lead-time resource projects to be able to defer or “roll over” their TPD allocations.  Enabling deferment to at least one subsequent cluster, for projects demonstrating site control, would reduce the time between when a PPA needs to be signed and the expected online date for transmission upgrades, such that LSEs can more reasonably be expected to enter into contracts.  Enabling such roll-overs would allow developers to provide earlier indications of commercial viability for resource areas that the CPUC has identified as promising based largely on high-level computer modeling.  The CAISO will also need to see such indications before commencing construction on approved transmission projects.  As noted above regarding EO resources, encouraging earlier expressions of commercial interest will provide the CPUC with an indication of POIs of interest for future transmission upgrades. Allowing roll-overs will also encourage developers to begin their prospecting and development activities sooner rather than later.

In the alternative, CalWEA proposes that LLT resources receiving a TPD allocation under a Conditional Group be allowed to extend their “retention period” from one to three years.

The Straw Proposal states that “deferring deliverability allocations has the potential to delay other projects in the queue and the construction of network upgrades needed by future customers.”  CalWEA does not understand this concern.  The allocations will be made to resources of the type for which the transmission is being planned and reserved, so that capacity should not be available to customers using other resource types.  Moreover, as noted above, enabling rollovers will encourage prospecting and development of projects using appropriate resource types.

[1] https://www.ferc.gov/media/ad24-9-000-workshop-third-suppl-notice

[2] Specifically, CalCCA proposed the following additional requirements for operating EO projects:(1) that project deliverability requests be evaluated under the full set of existing ISO criteria, (2) that the PPA focus on the resource’s RA element, and (3) that a reasonable cap be set for how often, and how frequently, an EO project may reapply.

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

No comment.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

No comment.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

No comment.

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

No comment. 

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

Section 2.6 Monitor trends in Energy-only (EO) interconnection requests for alignment with resource portfolios 

While CAISO commits to monitoring trends in EO IRs for alignment with resource portfolios, there is no clear proposal to address the present need for Energy Only resources in CPUC’s latest resource portfolios.  

In response to Clearway and LSA’s recommendation to allow projects that fail to get deliverability to switch to Energy Only rather than being removed from the queue, CAISO indicated that the ISO sees no need to allow such a transition and that such a change would run counter to the ISO’s objective to create clear and certain timelines for interconnection customer and PTOs. Clearway understands the CAISO’s concern about opening this option to all projects that are not allocated TPD, but recommends that projects that fail to get deliverability should only be allowed to convert to Energy Only under a set of clear criteria including but not limited to showing (i) commercial viability in the form of an Energy Only power purchase agreement and (ii) evidence of specific development milestones within a certain time after the FCDS to EO conversion, Projects that fail to do so should be deemed withdrawn. This will provide clear and certain timelines for interconnection customers and PTOs.  

Projects seeking FCDS status in Cluster 15 or later would have entered the queue based on the advanced development status and substantial financial commitments. These projects have surpassed key readiness thresholds. Some of these projects may be viable either as deliverable or Energy Only resources. Considering the projected energy demand outlined by PG&E  for the 2028–2032 timeframe under the RCPPP, it would be prudent to permit their transition to EO. To maintain the integrity of the EO portfolio, a screening mechanism based on commercial viability and development milestones could be introduced to ensure only robust and feasible projects move forward. 

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

Section 3.1 Allowing operational Energy Only projects to seek deliverability 

• Clearway supports CalCCA’s proposal to enable operational Energy Only (EO) projects to pursue deliverability, provided they can demonstrate a Resource Adequacy (RA) power purchase agreement in addition to an EO agreement. CAISO should consider allowing Energy Only (EO) projects to utilize available deliverability given the uncertainty in projected Long Lead-Time (LLT) resource development. This approach could serve as a practical contingency plan, aligning with CAISO’s request to the CPUC for a back-up strategy under the RCPPP framework.  

• Furthermore, Clearway continues to recommend the establishment of a pathway for EO projects located in Merchant zones to access Transmission Plan Deliverability (TPD), should those zones be designated as TPD-eligible in the future. IPE 2023 Track 2 did not address how CAISO will handle the evolution/transition of a Merchant zone into a TPD zone. To avoid unnecessary queue churn and stranded transmission capacity, EO projects in a merchant zone that meet certain commercial viability and development milestones should be allowed to access any incrementally created TPD. CAISO indicates that they would like to see trends emerge both with the proportion of Energy Only versus deliverable projects as well as merchant versus Transmission Plan Deliverability (TPD) zones. While Clearway appreciates the need to study such trends, we would encourage CAISO to think about how within a span of one year the queue composition of Energy Only vs FCDS projects has changed. There is already a trend emerging in Cluster 15, for example during the stakeholder call CAISO mentioned that 30% of Cluster 15 projects are EO. This is a significant departure from previous clusters, for example only 10% of total MW at POI were EO prior to Cluster 15. CAISO’s projected resource need based on the latest CPUC portfolios is ~63 GW by 2035 and ~99 GW by 2040. Median time from Interconnection Request to COD was 75+ months for projects that became operational between 2018 and 2024. This time it is only likely to increase based on Cluster 14 results. Considering the resource need, upgrade delays and extended resource development cycle, Clearway recommends CAISO to reconsider the option for “ready” projects in the queue to seek TPD in case of a merchant zone to TPD zone transition. 

• To address CAISO’s concern that EO projects will endlessly wait in the queue for TPD to become available, CAISO should create readiness criteria including but not limited to (1) demonstration of commercial viability in the form of a PPA to meet RA and (2) demonstration of key development milestones related to permitting, design, engineering and construction.. This approach aligns with CAISO’s existing readiness standards and supports a 'first ready, first served' principle, ensuring that credible, advancing projects are not disadvantaged by procedural delays. 

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

4.2. Adjust required generator interconnection agreement (GIA) execution to be after all deliverability allocations are complete 

Clearway recommends that CAISO allow projects to delay execution of their LGIA until after the first deliverability allocation results are known. Clearway understands that projects in C15 and onwards are subject to FERC Order 2023 requiring fixed study/LGIA timelines and results in decoupling of LGIA execution and TPD outcome milestones. Clearway feels that instead of a total decoupling of these two, CAISO should take into consideration its traditional practice during the pre-C15 TPD allocation process which has allowed projects two chances to seek TPD before LGIA execution. Clearway understands that if CAISO follows the same suit and allows projects three deliverability chances before LGIA execution, it may result in projects staying in for three years only to drop out of the queue without any stepped-up commitment.  

Therefore, as a middle ground, Clearway believes providing a project with the opportunity to complete a single TPD allocation process prior to executing an LGIA is a reasonable ask that enables developers to assess the viability of a project before committing significant financial capital and encourages projects that are not likely to receive TPD to exit the queue quickly within first year of allocation. In addition, even if a project waits on TPD allocation results and doesn’t execute LGIA, it cannot avoid posting security and provide NTP for the shared network upgrades per recent tariff provision and thereby would not cause any delay to other projects with such shared network upgrade in achieving their COD. 

4.3 Provide consolidated and searchable data on network upgrades 

Clearway recommends that CAISO re-name the current title from ‘consolidated and searchable data on network upgrades’ to ‘Interconnection feasibility data availability prior to queue entry’ as the information CAISO has agreed to share covers many items beyond network upgrades. 

Clearway is supportive of the ISO considering stakeholder requests to share updated POI information at the key milestones in the study process. Clearway recommends that the ISO make data available after these milestones: 

• After deliverability allocations  

• After approval of the annual transmission plan 

• After each cluster queue is posted 

• After reassessment results 

4.5. Responses to additional stakeholder comments 

Clearway recognizes a very important enhancement CAISO made by offering access to RNU headroom by implementing Intra-cluster Prioritization. Building on this same framework Clearway recommends that CAISO create a similar process for more “ready” projects to access deliverable capacity that exists on the network while projects wait for long lead-time upgrades or upgrades that are delayed and needed to achieve deliverability. The current intra-cluster prioritization offers a clear path for more ready projects to interconnect before all RNUs are in-service. The benefit from this enhancement of early interconnection pathway can only be fully realized if projects are also offered a path to early deliverability.  

Several projects Cluster 14 and earlier have been waiting or delayed deliverability network upgrades. These projects have FCDS status, have posted the 3rd financial security with significant capital at-risk and are also able to bring the EO portion of the resource online early. Clearway has tested at least one study area where significant deliverability is available for resources that are ready to be online several years in advance of the deliverability upgrade timelines. What prevents the use of this available deliverability is the lack of contractual certainty of deliverability in the interim years. Clearway feels that the intra-cluster prioritization and TPD allocation scoring processes provide CAISO with a solid template to offer any deliverability that may be available while projects wait for long lead-time deliverability upgrades. Use of scoring criteria including but not limited to (1) demonstration of commercial viability in the form of a PPA to meet RA and (2) demonstration of key development milestones related to permitting, design, engineering and construction. will solve CAISO’s concern about infinite study scenarios to be tested.  This approach aligns with CAISO’s existing readiness standards and supports a 'first ready, first served' principle, ensuring that credible, advancing projects are not disadvantaged by procedural delays.  

In prior discussions about a similar proposal, the CAISO raised concerns that allocating interim deliverability for multiple years could result in a later-queued project receiving Interim Deliverability in place of an earlier-queued project. We understand the CAISO’s concern and propose a modification to respect the priority of earlier-queued projects. Scoring and allocation of Interim Deliverability should occur annually and should include all projects in all queue clusters. A project that receives Interim Deliverability through this process may retain it for multiple years, unless an earlier-queued project receives a score that is the same or higher. This modification would include more risk for projects receiving Interim Deliverability but would still be a significant improvement from the status quo that would enable projects to contract and come online.  

Until now, this issue was primarily limited to projects that were affected by delayed upgrades but moving forward several GW of queued projects with FCDS are going to rely on TPP upgrades that won’t be completed until the first half of the next decade. Clearway encourages CAISO to offer a pathway for projects to access available headroom behind completed upgrades while waiting for long lead-time upgrades.  

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

5.3. Modify the commercial readiness deposit due date 

Clearway recommends that the PTO should post the latest pro forma security templates on their website 3 months prior to due date. This would allow for sufficient time for the IC and the PTO to agree to changes to pro forma. 

5. Provide your organization’s comments on section 6: WEM Governing Body Role

N/A

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

Additional topics:

Affected system delay treatment same as CAISO PTO delay 

Clearway recommends that CAISO allow projects to extend COD without having to demonstrate CVC if the COD extension is driven by affected system study and upgrade delays. This treatment would correspond to CAISO’s treatment of CAISO PTO network upgrades. Many of Clearway’s projects have affected system studies outside the CAISO PTO.  When an interconnection customer shows proof that it has reached out to the affected system outside the CAISO within a certain number of days (60 for example similar to affected system’s required timeline for identification once notified by CAISO) after facilities study report, then the outcome of an affected system result, such as not releasing affected system claims until the network upgrade identified in their study is complete, should be treated similar to CAISO PTO’s network upgrades. Clearway recommends that in those circumstances the IC should be allowed to extend the COD until network upgrade identified in their study is complete without the need to show CVC. 

MMA - allow for sensitivity runs with additional PTO time 

PTOs do not make the models used for MMA evaluation available to IC. The PTOs evaluate MMAs using the latest information they have, but that information is only made available to the public via the MPP, which only is updated a few times a year. Therefore, it is difficult to predict the outcome of an MMA (especially for small technical parameter tweaks) and subsequently wait on MMA decision that takes up to 6-9 months. A minor modification in the technical data may change an MMA from rejected into an approved. Clearway would like to seek the ability for an IC to request one additional sensitivity analysis in addition to baseline MMA analysis. CAISO can extend existing turnaround time or deposits to accommodate such requests. 

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

About Eddy Energy

Eddy is a U.S. distributed energy storage development platform.  Eddy works with landowners, communities, and load-serving entities to develop fleets of stand-alone storage projects that efficiently deliver needed local reliability benefits along with peak energy-shifting necessary to integrate renewables.  Eddy is based in San Francisco, CA.

Allow Operational Energy Only Projects to Seek Deliverability

Eddy supports CalCCA’s proposal to allow operational Energy Only projects to seek deliverability.  In it’s Proposal, CAISO asks proponents of such an approach to ‘articulate the problem the ISO would be solving.’  Our response to that is that one of the principal problems is the lack of any path to RA for a large share of WDAT projects—that is, the projects interconnected under Fast Track.  Per the WDAT tariffs of each IOU, Fast Track interconnections (which are up to 3-5 MW) must only be Energy Only and are ineligible from joining Deliverability studies during their interconnection phase.  It’s hard to see how preventing these smaller projects, which can be sited directly in load centers and provide valuable support to the distribution grid, from even being considered for Deliverability is in the State’s interest.  If these smaller projects can pass the screens currently defined in the WDAT and come online as Energy Only assets, providing peak shifting and other attributes that are valued by local offtakers, there is no reason why they shouldn’t be able to be studied for Deliverability on the same basis as other proposed generators.

Furthermore, SDG&E has actually proposed to eliminate the Independent Study Process in its WDAT tariff, as filed with FERC.  SDG&E argues that the Fast Track represents the best route to develop distributed resources in its territory.  Thus, if developers are left with only Fast Track as the process in SDG&E territory, surely it is reasonable to ask that there be a route for these projects to seek Deliverability.

Provide Alternate Pathways towards RA for Distributed WDAT Projects

Alternatively, Eddy advocates for potential other pathways towards RA credit for smaller, distributed projects.  Presently, the DGD Allocation process is not a workable pathway for new distribution-connected projects, as this process merely allocates leftover Deliverability in very small quantities in locations that are impossible to predict.  While allocating Deliverability across the system to transmission-connected resources is of utmost importance, it’s also in the State’s interest to establish a reasonable pathway towards providing local reliability for distribution-connected resources that serve local load and do not export to transmission.

The CPUC itself identifies large DERs as a high-value asset class that is currently challenged by a lack of pathways in California.  According to the CPUC’s Energy Storage Procurement Study, distribution-connected storage assets have the potential to deliver the highest benefit-to-cost ratio out of all storage asset classes, but the report states that, to achieve this, programs for these resources must “enable multiple use applications by requiring distribution-connected resources to offer transmission grid-level services when idle and minimize extended periods of standby.”[1]   We urge the CAISO to recognize the potential for resources that use the local distribution system to provide grid benefits, including RA, and help provide reasonable pathways for these resources to deliver this local capacity.

Respectfully submitted,

Sam Maslin

CEO

Eddy Energy LLC

[1] https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/energy-storage/2023-05-31_lumen_energy-storage-procurement-study-report.pdf

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

EDF power solutions (EDFps) appreciates the California ISO's (ISO) leadership in the Interconnection Process Enhancements 5.0 initiative and thank you for the opportunity to provide comments on the Straw Proposal. Our feedback is offered in a spirit of constructive engagement, guided by the overarching principle that an effective interconnection process must provide regulatory certainty, maximize the use of viable and operational assets, and empower developers with the information needed to make efficient decisions. We look forward to working with the ISO and stakeholders to ensure the final proposal helps achieve California's urgent reliability and policy goals. 

Section 2.5. Clarify long lead-time resource eligibility for system need points 

EDFps appreciates the ISO's work to establish a process for identifying long lead-time (LLT) resources through the transmission planning process. However, for this process to be effective, it must provide upfront regulatory certainty for developers investing in novel and long-duration technologies. The process described, where a list is developed annually, does not fully resolve the investment risk associated with last-minute eligibility changes. 

To foster development of the diverse resources California needs, we recommend the ISO go further by establishing clear and durable eligibility principles. Specifically, we propose that the ISO clarify that any resource technology eligible for procurement by a state entity, such as the Department of Water Resources (DWR), will automatically qualify for LLT system need points in the interconnection intake process. Adopting this principle would provide the necessary forward-looking certainty for developers to invest in non-lithium long-duration energy storage (LDES) and other innovative technologies, aligning the interconnection process directly with state procurement goals. 

Section 2.7. Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes 

EDFps recommends that the ISO defer the inclusion of Wholesale Distribution Access Tariff (WDAT) projects in the intake scoring process at this time and instead explore a more holistic integration strategy. 

The experience in Cluster 15 highlights the need for a more thoughtful approach. In that cluster, WDAT projects seeking deliverability in Transmission Plan Deliverability (TPD) zones were accepted into the study process but were then immediately informed they were not allocated deliverability. This outcome demonstrates that simply admitting WDAT projects into the study process does not provide a meaningful pathway to compete. Forcing this large volume of projects into the already highly constrained intake scoring process would add significant uncertainty for transmission-level projects without resolving the underlying issue of how WDAT projects can fairly and effectively be evaluated for deliverability. EDFps requests the ISO gather information to identify the root cause of the WDAT mass disqualification.  

Furthermore, the current WDAT queue consists almost entirely of standalone battery energy storage systems (BESS) in SCE's territory. Because Load-Serving Entities (LSEs) are reportedly already long on standalone BESS procurement, the immediate risk of these specific WDAT projects consuming limited TPD capacity may be low. This situation provides a valuable window of opportunity for the ISO to work with stakeholders to design a more gradual and effective integration mechanism, rather than introducing another major variable into the recently reformed intake process. 

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

Section 3.1. Allowing operational Energy Only projects to seek deliverability 

EDFps strongly urges the ISO to reconsider its position and re-establish a pathway for operational Energy Only (EO) projects to seek deliverability by re-entering the interconnection queue. The ISO’s current proposal to keep this pathway closed misses a critical opportunity to leverage existing, viable assets to meet California's reliability needs. 

The rationale for this change is threefold: 

1. Commercial Viability: Achieving commercial operation is the ultimate demonstration of a project's viability. The ISO’s own scoring system recognizes this by awarding additional points to operational projects during intake. Prohibiting these proven assets from ever seeking deliverability is inconsistent with the goal of advancing the most viable projects. 

2. Changing Grid Conditions: The landscape for TPD is fundamentally different than in the past. With TPD availability severely constrained and the timelines for network upgrades growing longer, the grid needs creative, efficient pathways to bring capacity online. Allowing operational EO projects to compete for deliverability as it becomes available is a low-cost, high-value option to enhance grid reliability. Stranding these operational assets as EO in perpetuity is an inefficient use of resources. 

3. Essential Market Signals: The CPUC’s inclusion of EO resources in its Transmission Planning Process portfolios indicates a recognized need. Allowing these projects to seek deliverability provides a crucial forward-looking signal to both the CPUC and the ISO, identifying locations where viable generation already exists and informing where future TPD upgrades are most needed. The current process risks creating a feedback loop where development is only driven to areas with existing TPD, potentially ignoring other optimal locations. 

We share the ISO's goal of ensuring queue integrity and appreciate the need to weigh the 'benefits and risks' of this pathway. We believe the significant financial and temporal commitments required to re-enter the queue serve as a strong, inherent deterrent, ensuring that only developers with a serious intent to secure a resource adequacy contract would pursue this option.?Such approach is also one that is widely used across other ISO/RTOs in North America with no restriction on an interconnection customer to go back to the queue to seek deliverability if it wishes to do so, in full alignment with open access principles. 

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

Section 4.3. Provide consolidated and searchable data on network upgrades 

EDFps supports the ISO’s commitment to improving data availability for interconnection customers. To make this effort truly effective and to support the goal of reducing speculative queue entries, we urge the ISO to expand its data transparency efforts to include greater insight into and regular reporting of  interconnection costs. 

Currently, the complete absence of publicly available information on network upgrade costs for competing projects makes it exceptionally difficult for developers to conduct meaningful competitive analyses and make informed project siting decisions. This information asymmetry hinders the market's ability to self-select the most economically efficient projects. 

We request that the ISO explore mechanisms to publish redacted or aggregated cost data from past cluster studies. Providing this information would empower developers to better assess the financial viability of potential interconnection locations, leading to more informed and less speculative queue entries, which directly supports the foundational goals of the IPE reforms.? 

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

Addressing the ISO as an Affected System in IPE 5.0 does not go far enough in resolving the Affected Systems issues facing ISO interconnection customers. EDFps urges that affected system is incorporated into IPE 5 or be the topic of a separate initiative dedicated to affected system which has become a large challenge in the West. For instance, several entities are experiencing large delays with conducting affected system studies, or have yet to implement cluster study methodologies. Cluster studies provide opportunities for efficiencies but also create the risk of multiple restudies and delays based on how clusters are being prioritized across various balancing authorities (BAs), queue withdrawals and potential resource constraints impacting BAs. This can in turn impact ability of interconnection customers in CAISO to come online or move through the queue with certainty over affected system cost and timelines. Transparency in study methodologies, modeling assumptions and cluster prioritization is also a topic that should be elevated in stakeholder discussions.  

5. Provide your organization’s comments on section 6: WEM Governing Body Role

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

EDFps appreciates the ISO's continued efforts to refine the interconnection process. Our comments are guided by the overarching principle that the process should provide regulatory certainty, maximize the use of viable and operational assets, and empower developers with the information needed to make efficient decisions. We believe that incorporating our feedback will better align the IPE 5.0 initiative with California's urgent reliability and policy goals.? 

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

The Independent Energy Producers Association (IEP) is California’s oldest and leading nonprofit trade association, representing the interests of developers and operators of independent energy facilities and independent power marketers. IEP members collectively own and operate approximately one-third of California's installed generating capacity, which is derived from solar, wind, geothermal, hydropower, hydrogen, biomass, natural gas, and energy storage resources. IEP appreciates CAISO's commitment to revisting the 2023 Interconnection Process Enhancements (IPE) and respectfully submits the following comments.

Transparency, rigor, and integrity of the Load-Serving Entity (LSE) commerical interest point allocation process: Although CAISO posed the question of treating the Department of Water Resources (DWR) as an LSE for purposes of the commerical interest point allocation for the long lead-time resources to the CPUC, IEP wishes to offer support for this proposal. As first recommended by Invenergy, IEP supports the DWR being recognized as an LSE so that it may award commercial interest points for the long lead-time resources that will require interconnection in the coming years. DWR is mandated to procure these resources; therefore, there is guaranteed commercial interest in these projects and the point allocation should reflect as much.

Non-LSE commercial interest process: As noted in our original comments to the 2023 IPE, the non-LSE interconnection requests should receive at least 50 commercial interest points and LSE interconnection requests should receive at most 75 points. As load forecasts are increasing exponentially due to data centers, manufacturing, and overall electrification of our economy, it will be critical for the energy resources made to serve those increased loads be allotted commercial interest points that reflect their value. Without these energy projects, data centers, manufacturing, and other load intensive electrification development will move out of the state, leading to the underutilization of California's abundant renewable energy resources and major revenue loss.

Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes: IEP offers support for the CAISO's proposal to require any distributed projects seeking to participate in the ISO markets with deliverability to take part in a cluster deliverability study. Wholesale Distribution Access Tariff (WDAT) projects and similar distributed energy resources should take part in the study because these projects will eventually impact the Transmission Planning Process (TPP) and having the study information prior will lead to a more accurate TPP.

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

Allowing operational Energy Only projects to seek deliverability: Although CAISO is not proposing changes at this time, IEP writes in support of Invenergy's proposal for Energy Only (EO) projects be allowed to seek delvierability by re-entering the interconnection queue to be re-studied. Allowing EO projects to re-enter the queue will reduce timelines in comparison to new builds. Shorter timelines for EO projects to become distribution projects will reduce costs and add more resource adequacy resources to the grid at a time when we anticipate exponential load growth.

Consideration of allowing long lead-time resources to defer seeking deliverability: IEP supports Invenergy's proposal to allow long lead-time resources to defer seeking deliverability and roll over existing Transmission Plan Deliverability (TPD) allocation into future cluster applications. By their very nature, long lead-time resources take time to develop and are necessary to meet the grids needs in coming years. 

Deliverability reservations for projects waiting for long lead-time delivery network upgrades: IEP supports EDF Renewables' proposal to allow projects waiting for long lead-time delivery network upgrades to retain deliverability because CAISO is the entity that approves the network upgrades. In recent years, independent power producers have waited upwards of ten years to receive sufficient network upgrades and have lost deliverability in the interim. This can be cured in part by allowing deliverability reservations for these projects. 

Adjust required generator interconnection agreement (GIA) execution to be after all deliverability allocations are complete: IEP agrees with Invenergy's assertion that retaining the existing FERC Order 2023 generator interconnection agreement (GIA) timeline could result in the interconnection customer executing the agreement before knowing the deliverability has been allocated. An increase to the Commercial Readiness Deposits (CRD), paired with the requirement to execute GIAs while making monthly payments without deliverbility allocations is impractical. If the CAISO retains the FERC Order 2023 GIAs, then the timeline for deliverability must be changed as well. Independent power producers are required to front load too much risk without deliverability allocations and a limit of three deliverability allocation requests. 

Explore process changes to align with near-term procurement discussions: H.R. 1 (19th Congress, 2025-2026) and the United States Department of the Treasury's August 2025 guidnace on "beginning of construction" have drastically shortened the timeline to receive the Inflation Reduction Act's tax credits to build wind and solar resources. The CAISO, along with all other California agencies with relevant jurisdiction, should review all methods to reduce timelines for projects to begin construction. IEP recommends CAISO identify where interconnection requests are likely to be located based on the busbar mapping prior to interconnection requests submissions. Further, IEP requests CAISO create and maintain a list of energy projects that have previously been denied interconnection requests due to a lack of interonnection that remain ready and able to connect. Once interconnection becomes available, these projects will move from EO to deliverable immediately. 

Managing the accumulation of stagnant projects in the queue: IEP supports extending commercial operation dates (COD) beyond three years due to equipment acquistion delays and project development limitations created by recent federal government activity. Currently, energy projects are waiting more than three years to receive equipment essential for operation. Additionally, the existing congress that passed H.R. 1 will likely still be in office within three years, limiting the COD of certain technologies, like solar and wind projects. Litigation or policy changes could make way for solar and wind resources currently stymied by the federal government to more easily go forward, but both of those options will likely stretch beyond three years. IEP recommends extending the COD to eight years as proposed by Pacific Gas & Electric.

Modify the commercial readiness deposit due date: IEP supports CAISO's proposal to modify the commerical readiness deposit due dates to be due after the successful completion of the scoring and ranking steps. However, IEP recommends the CAISO go further and modify the due date until after the interconnection request validation. Otherwise, if the depost is requested earlier than after the interconnection request validation, the deposit should be refundable if it is rejected due to a lack of interconnection. 

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

Address timing issues for projects with long-lead-time DNUs

Intersect Power supports other stakeholders’ proposal to implement an Intra-Cluster Prioritization process for DNUs where projects are able to secure FCDS rather than request IDS every year. We understand that not all projects would be able to secure that FCDS status, especially projects with lower priority, however for older projects with more senior priority, there may be available headroom that could be guaranteed for future years regardless of when the DNUs would be brought online. This could provide the necessary certainty for ICs to bring projects online earlier.

Adjust the large generator interconnection agreement (LGIA) execution to be after TPD allocation

Intersect Power urges the CAISO to reconsider allowing QC15+ projects to delay their LGIA execution, at least till after the first TPD allocation cycle results, for the following reasons:

• Risk of Network Upgrade delays: The CAISO’s intention to ensure that Network Upgrade construction for “first-ready” projects remains on schedule is valid and can be achieved via execution of Engineering & Procurement agreements rather than GIAs by such first-ready projects. This is also achieved by the CAISO Tariff that requires other projects to make the necessary postings for shared Network Upgrades as soon as any one project makes their posting to kick them off, to avoid any delays.
• Abandoned partially completed NUs: Imposing an early GIA execution that precedes TPD allocation, will likely result in a series of abandoned partially completed NUs that were initially triggered by projects in the queue, that ended up not receiving TPD allocation and withdrawing from the queue, rendering such upgrades unnecessary.
• GIAs may include Infeasible CODs: By executing a GIA ahead of receiving TPD allocation, Interconnection Customers may be signing up to an infeasible COD that would require extension should they not receive TPD allocation or should their TPD allocation be contingent on long lead time DNUs.

Provide consolidated/searchable Network Upgrade data

Intersect Power appreciates the CAISO’s proposal to share redacted versions of individual project study reports. However, we support LSA’s request that the CAISO provides Deliverability mapping data after completion of the 2025 TPD Allocation process in March 2026, as well as after the 2025-2026 Transmission Plan is completed in May 2026. This data should be released as soon as possible in preparation for the Cluster 16 intake process, to ensure Interconnection Customers have enough time to secure land rights and site their projects.

Explore process changes to align with near-term procurement discussions

Intersect Power appreciates the CAISO’s willingness to consider solutions for an expedited timeline for projects that can be brought online ahead of the federal tax credits sunset date, and recommends the below to support Interconnection Customers (IC) in accelerating their timelines:

1. Increased oversight on PTO-led Network Upgrades and more visibility for Interconnection Customers onto expected delays.

• PTO reports indicate that more than 60% of planned upgrades are experiencing delays averaging 4.4 years, effectively doubling their timelines. The Transmission Development Forum, while helpful to inform updated NU ISDs, does not provide much details or justification of expected delays, nor does it open the door for the potential collaboration between PTOs and ICs to find creative solutions to bring in ISDs (e.g. leveraging ICs’ supply chain for potential procurement acceleration).

2. A consistent & proactive procurement approach across different PTOs

• Historically, different PTOs have provided different vendor and factory requirements to ICs. PTOs should agree on a combined vendor list and vendor factory list to streamline the procurement of equipment needed for Network Upgrades. This would also allow them to benefit from the below:

  • Create larger purchasing power across PTOs

  • Create an emergency pool of equipment that could be shared across PTOs during times of crisis (e.g. wildfire recovery)

  • Execute larger, cancelable capacity reservations in anticipation of future needs (cancelation costs can limit cost liability of Network Upgrades that may eventually not be required). This can also significantly reduce network upgrade timelines by shrinking procurement lead times, notably for Short Circuit Duty Upgrades, where breakers lead times can span multiple years

• Additionally, it is unclear why certain PTOs may deem certain vendors/factories to be satisfactory, while others do not, while all such PTOs are operating facilities included in the CAISO system. It's unclear how the system can be deemed reliable if that's truly the case, since a major failure in one PTO's service territory will almost certainly have cascading impacts in another PTO's territory.

3. Implement 'no-regrets' upgrades

• The CAISO and CPUC should explore 'no-regrets' upgrades that are almost certain to be triggered with future generation build-out, such as circuit breaker upgrades necessary to address Short Circuit Duty impacts. The latest IPE changes, which restrict Interconnection Request intake to areas with available Deliverability, can now also help facilitate the determination of such upgrades.  

4. The CAISO should take a more active role in resolving Affected Systems impacts

• Affected Systems impacts are often challenging to address, and the CAISO currently lacks a formal process for resolving these impacts, requiring ICs to work directly with neighboring systems who don’t necessarily have a standard study methodology and generally have very little incentive to expedite their studies and finalize mitigation agreements. 
• Projects would highly benefit from the CAISO taking a more central role in evaluating and resolving Affected Systems impacts in the interconnection study process. At a minimum, the CAISO should impose timeline constraints for Affected Systems to complete their studies, determine impacts, execute a mitigation agreement, and avoid delays to projects energization.

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

Managing the accumulation of stagnant projects in the queue

Intersect Power strongly supports the CAISO’s efforts to reduce the queue backlog and get non-viable projects to drop from the queue. CVC should be applicable to all projects seeking COD extensions beyond 7 years, including Energy Only projects, and not just those seeking to retain Deliverability.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2.1. Transparency, rigor, and integrity of the Load-Serving Entity (LSE) commercial interest point allocation process:  Invenergy again recommends that the CAISO include the Department of Water Resources (DWR), as the Central Procurement Entity (CPE) for certain LLT resources (including 7.6GW of OSW) under AB 1373 and CPUC R.20-05-003[1]), under the LSE Commercial Interest points framework. 

While DWR is not an LSE per se, the new framework effectively just substitutes DWR procurement of the specified resources for LSE-mandated procurement of the same resources, in the interest of efficiency and in recognition of the large and long-term commitments involved. 

DWR competitive solicitations are expected to commence in or around  2027, and it is possible that it may be in a position to award CI points for Cluster 16 projects before that, with sufficient notice that it will qualify for that process and perhaps outreach from the CAISO.

If DWR cannot participate in the process that soon, CAISO should consider alternative methods for LLT resources to gain the equivalent of CI points in the intake process.  It is logically inconsistent for the CAISO to reserve TPD for LLT resources but make it difficult for them to enter the queue and use those reservations.

[1] See information posted at https://www.cpuc.ca.gov/-/media/cpuc-website/divisions/energy-division/documents/integrated-resource-plan-and-long-term-procurement-plan-irp-ltpp/ab1373/final_decision_-ab1373_factsheet_pdf.pdf.

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

3.1. Allowing operational Energy Only projects to seek deliverability:  Invenergy supports the ability of projects that have already demonstrated their commercial viability as Energy Only projects being allowed to use available deliverability; in fact, they would be able to use it right away, to the potential benefit of the system, as opposed to newer resources that have yet to reach COD and could still have impediments to successful development.

3.2  Allowing LLT resources to defer their first attempt to seek deliverability:  Invenergy urges the CAISO to reconsider its reasoning for not proceeding with this sensible suggestion.  It is no surprise that developers of non-LLT resources are not supportive of additional measures to accommodate LLT resources, though their technologies have been recipients of numerous accommodations under the CAISO tariff over the past several years.[1]

The standard here should not be whether the proposal is popular, but whether it is sensible and is in the state’s best interest.  Allowing LLT resources to defer their initial TPD Allocation requests would be both, among other proposals.

It is inconsistent for the CAISO to reserve TPD for LLT resources but then place obstacles to their actual acquisition of TPD.  LLT resources simply have longer development timelines than conventional projects, and it would be good policy for the CAISO to implement rules that recognize that fact.  This proposal would also be consistent with the Federal Power Acts mandate prohibiting undue discrimination that resources that are not similarly situated should not be subject to the same rules as everyone else.

[1] Those accommodations have included development of the Participating Intermittent Resources Program (PIRP), different Must-Offer Obligations and the Eligible Intermittent Resource (EIR) forecasting framework for Variable Energy Resources (EIRs), the LCRIF concept, the Aggregate Capability Constraint framework for Mixed-Fuel Resources, Multi-Stage Generator (MSG) modeling and operating rules, and the Limited Energy Storage Resoruce (LESR) framework and other special energy storage operating rules.

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

4.4 Explore process changes to align with near-term procurement discussions:  As indicated by our comments above, there continues to be a mismatch between LLT resource procurement activities in the market like the timing for state-run solicitations for LLT resources, and CAISO tariff processes, including Interconnection Request intake and TPD Allocation request timing. 

Allowing DWR to participate in the intake process as an LSE, and potentially allowing deferral of LLT initial TPD Allocation requests, are important steps CAISO can take to improve that alignment.  We also strongly support CAISO’s continued exploration of additional accommodations that help align procurement and interconnection in the future.[1]

Some of these solutions might include explicitly tying the timing of CAISO deliverability to the state solicitation process.  For example, there is no reason why allocations of reserved TPD to LLT resources need follow the same schedule as the regular TPD Allocation process. 

Instead, since the CAISO is reserving TPD for LLT resources, the CAISO could time initial and subsequent allocations of that reserved TPD to LLT resources to coordinate with AB1373 procurement activities.  The CAISO could effectively hold separate LLT TPD Allocation processes after DWR procurement cycles, for example.

[1] The Straw Proposal notes that the CAISO will explore “[a]lignment between procurement and interconnection milestones.” Straw Proposal at p. 5.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2.1 Transparency, rigor, and integrity of the LSE allocation process:  LSA is willing to wait and see the input from Local Regulatory Authorities on this issue.  However, LSA notes that:

• The “Local Regulatory Authorities” for many LSEs - namely, Publicly Owned Utilities and associations – is basically the LSEs themselves.  In other words, those LSEs are basically regulating themselves. 

• The process for other LSEs had literally no regulatory oversight in the Cluster 15 intake cycle, and the demands made by several large LSEs – including exclusivity requirements and non-refundable deposits – will simply solidify LSE monopsony power and reduce competition in the future.

2.2 Non-LSE CI process:  LSA is also interested in the input CAISO has requested from non-LSEs.  LSA notes that concerns about LSE monopsony activities and unreasonable concessions could be ameliorated by expanding the pool of potential off-takers so there are more opportunities for CI points.

LSA suggests that the CAISO establish outreach efforts to these types of entities, who may not even be aware of their opportunities to participate in the interconnection process in this manner.  For example, several new data centers (large consumers) are planned in the CAISO BAA, and organizations representing large electricity users (e.g., CLECA) typically do not get involved in CAISO interconnection initiatives. Many of these entities might be interested in encouraging new generation and storage facilities to locate in their areas, for reliability and other purposes.

LSA continues to believe that non-LSEs wishing to participate in the CI process should have the option to demonstrate that their load-serving interest is broader than one project (e.g., retailers or data-centers with multiple locations).  They should be allocated CI points proportional to their load, and allowed to award them to any number of projects. 

The CAISO could add registration requirements for non-LSEs making this election, similar to those for LSEs.  To the extent that non-LSEs make this election, their points could be subtracted from those of LSEs serving the same areas, to avoid double-counting.

Non-LSE CI points should be allowed to total the same 100 points for a project as LSE CI points.  The CAISO’s concerns that PPAs with non-LSEs are somehow inferior to or less certain than those with LSEs have no evidentiary support.  Entities qualifying for the expanded participation LSA recommends would likely be large, established companies (larger than many LSEs) with extensive procurement organizations and experience, and there is no reason to expect that their contractual commitments are any less robust than those from LSEs.

2.3 Revisit the cap on full allocation election to small LSEs and revise as appropriate:  LSA is not opposed to including consideration of a higher cap in the IPE 5.0 scope than the current 125% cap, provided that self-builds are excluded.  

LSA supports the NCPA proposal to allow small LSEs to sponsor resources above the cap to replace retiring LSE-owned resources under this framework.  For example, if an LSE has a 100MW CI points allocation (125 MW single resource-sponsor limit) and a 200MW resource retiring, it should be able to sponsor 200MW of new resources, even if that new capacity is spread over several projects, assuming that they are not self-builds of that LSE.

Limiting the higher cap to market arrangements will increase competition and mitigate what might otherwise be increased concerns about self-dealing at the higher capacity levels.     

2.4 Methodology for award of commercial interest points based on requested interconnection service capacity:  LSA continues to believe that Mixed Fuel Resources (MFRs) should be allowed to split into FCDS and Energy Only portions in the intake process, instead of being subject to FCDS scoring for the entire project even where deliverability is sought for only a small portion of the capacity.

The Proposal does not include this change.  At the 8/11 meeting, the CAISO noted that no Cluster 15 PCDS projects had been submitted, or separate projects of different fuel types (e.g., solar and storage) at the same POI by the same developer, and concluded that allowing separate consideration of FCDS and EO parts of the project for CI points purposes is not needed.

LSA replied that one reason the CAISO hadn’t seen PCDS projects in C15 may be that they were disadvantaged under the current structure.  Asked by CAISO to offer an example, LSA cited a hypothetical 100MW MFR with 50 MW of FCDS BESS and 50MW of EO solar.  This project would need 100MW of FCDS CI points to get 100 unweighted CI points (30 weighted points). 

The 50 MW of BESS would effectively “cost” an LSE 100MW of FCDS CI points, the same as a 100MW BESS project, which would provide much more RA.   

Aside from better matching the requested deliverability, encouraging mixed FCDS-EO MFRs to enter the queue more easily would support current policy directions by allowing better matches with CPUC directives.  MFRs with FCDS storage and EO solar or wind are highly encouraged under the CPUC’s “slice of day” framework, because the renewable component can count toward charging the BESS without being deliverable.   The CAISO should be encouraging such resources to enter the queue, not discouraging them with unfair point scoring.

LSA suggests that MFRs be allowed separate scoring for the FCDS and EO capacity, which would make it more likely that each portion would clear the scoring process.  If one part of the project clears the scoring process while the other does not, the developer could decide, during the Customer Engagement Window, to proceed only with the capacity clearing the scoring process or withdraw and try again next time.

This change would not impact projects with the more typical configuration where the storage and solar capacity each equal the Interconnection Service Capacity, but it would allow projects with less FCDS capacity proportionally to be scored more fairly.

2.5 Clarify long-lead-time (LLT) resource eligibility for system need points:  LSA does not object to addressing the LLT resource issue during the TPP, as long as the CAISO commits to listen there and not defer it to yet another forum.  LSA has asked why it is necessary for these large and increasing capacity reservations when new resources in the future cannot acquire and/or retain TPD Allocations without executed PPAs, and Local Regulatory Authorities should be exercising their authority to ensure that sufficient and diverse portfolios are procured based on their directives.  We are still awaiting a sufficient explanation, besides “the CPUC asked us to.”

LSA also notes that the CAISO has recommended, in the RCPPP, that the CPUC develop a back-up plan in case LLT resources do not materialize.  These TPD reservations effectively ensure that back-up resources cannot be ready, since they cannot even enter the queue under the current rules.

2.6 Trends in Energy Only Interconnection Requests for alignment with resource portfolios:  The Energy Only capacity accepted for study is already aligned with the CPUC Energy Only forecast by zone. The CAISO should also incorporate information from other regulatory authorities.

LSA continues to believe that the CAISO should provide an Energy Only option for projects that applied for interconnection as FCDS in TPD Zones but fail to secure a TPD Allocation.  Projects that pass the FCDS scoring rubric to be accepted for study, but then fail to secure TPD, have already cleared a high bar for "readiness" and likely committed significant capital. These projects should be allowed to convert to EODS, considering the energy need identified by PG&E and SCE in 2028-2032 as part of RCPPP. A Commercial Viability Criteria screen could be imposed to ensure only credible EO projects remain. 

Moreover, allowing these projects to qualify for a Commercial Group TPD allocation later could provide a valuable backstop in case these resources are needed for deliverability, e.g., if LLT resources do not materialize as expected (see below) or if load grows faster than expected. They would basically constitute a ready pool of ready resources for these purposes if needed.

2.7 Incorporation of distribution system interconnection projects into the intake scoring process and 150% study limit processes:  LSA supports the CAISO’s proposal and, further believes that the CAISO should also allow distribution-level projects dependent on long-lead-time Network Upgrades to participate in the Intra-Cluster Prioritization process.

However, this proposal needs to be more specific.  Note that PG&E’s new tariff Attachment K (Generator Interconnection Study Procedures (GISP)), filed in compliance with FERC Order 2023, retains both the Fast Track and Independent Study processes, and provides for Interconnection Requests submitted under both of those options to request deliverability.  (The SCE and SDG&E compliance filings eliminate the Independent Study option and require Fast Track IRs to be Energy Only.)  The CAISO should clarify how PG&E FT and ISP IRs can obtain deliverability, e.g., whether they must go through the proposed cluster-study process or can enter the TPD Allocation process directly, as they have been allowed historically.

The CAISO should also clarify whether the Deliverability for Distributed Generation (DGD) process is still open to all distribution-level projects.

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

3.1 Allowing operational Energy Only projects to seek deliverability:  LSA still sees no problem with projects that have already demonstrated their commercial viability as Energy Only projects being allowed to use available deliverability; in fact, they would be able to use it right away, to the potential benefit of the system. Also, as noted above, this change could provide a ready pool of resources in case LLT resources do not develop as expected or demand grows faster than forecasted.  In fact, allowing Energy Only projects to use available deliverability, at least until any LLT resources materialize, could be part of the LLT back-up plan that the CAISO has requested from the CPUC in the RCPPP.

3.2 Consideration of allowing long lead-time resources to defer seeking deliverability:   LSA agrees with the CAISO’s intent not to proceed with this earlier proposal.  LSA opposes special, discriminatory rules for these or other resource types and believes that the same rules should apply to all projects.

As discussed at the 8/11 meeting, the more efficient way to address this issue would be for the CAISO to urge the CPUC and other regulatory authorities to direct their jurisdictional LSEs to execute PPAs for these resources earlier, for projects in areas where deliverability is available – to better facilitate all aspects of their development, not just TPD Allocations.  The new AB1373 procurement processes being established by the state in 2027 for some of these resources should do the same.

That would allow these resources to adhere to the timelines applicable to other resources, instead of the CAISO establishing special rules for them. Timely procurement of desired resources in the right locations is the responsibility of regulatory authorities, not the CAISO.

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

4.1 Address timing issues for projects waiting for long-lead-time DNUs:  LSA agrees with Clearway and others that CAISO could and should expand this “headroom” concept to determine whether some projects behind deliverability constraints could receive FCDS before all the upgrades to mitigate those constraints are complete. Like the COD certainty provided by an RNU headroom award, this FCDS date certainty would better enable use of available deliverability and greatly aid projects in their PPA contracting.

4.2 Adjust the large generator interconnection agreement (LGIA) execution to be after all deliverability allocations are complete:  As discussed on the 8/11 call, this change is absolutely needed for C15 and later clusters, particularly for projects that do not receive TPD Allocations on the first try.

This became apparent as the meeting discussion proceeded, starting with the feasible COD.  If projects have to execute GIAs before they know whether they receive TPD Allocations, presumably those GIAs would be based on the CODs and related milestones from the Interconnection Studies. 

Optimistically, assume that the earliest achievable CODs in those studies reflect the length of the TPD Allocation process, so they would be feasible for projects receiving TPD Allocations on the first try.  That would suffice for those that do receive such allocations. 

However, this would be highly problematic for projects that do not receive TPD Allocations on the first try.  The GIAs that they must execute in order to stay in the queue for their additional tries would presumably have what would then be infeasible CODs.  They would have to initiate monthly payments, and PTOs might even be required to commence construction of upgrades based on those infeasible CODs, and the project owners could have to commence construction of a project that could be out of the queue two years later.

This course of action simply makes no sense.  LSA continues to believe that it is unreasonable and impractical to require projects to increase their Commercial Readiness Deposits, execute GIAs, and begin making monthly payments when they have no feasible CODs, and when they may have no projects at all after their allowed three TPD Allocation requests.  These requirements should be deferred until projects seeking FCDS know whether they will receive TPD Allocations.

If the CAISO does not allow postponement of GIA execution, at a minimum, projects that do not receive TPD Allocations on their first try should be allowed to extend their CODs (and associated payments and security postings) by a minimum of one year, with another one-year increment (and associated GIA amendment) allowed for projects that do not get a TPD Allocation by the second try.  This would at least postpone the need to commence PTO and developer construction for what may be infeasible projects.

4.3  Provide consolidated and searchable data on Network Upgrades:  LSA again asks the CAISO to commit specifically to at least two releases of POI/FCDS mapping data in preparation for Cluster 16 – an initial release after completion of the 2025 TPD Allocation process in March 2026, and a final release for the C16 intake process right after the 2025-2026 Transmission Plan is completed in May 2026.

CAISO should also publish substation-level interconnection feasibility data (substation access, known binary limitations, long-lead-time upgrades for short-circuit duty or bus limitations, etc.) well before queue entry, to support informed project siting and reduce speculative entries.  The CAISO said it would release information in redacted form for Cluster 15 projects, but none of that information will likely be available before the October 2026 opening of the C16 application window.

Early availability of this information is particularly critical due to the new Order 2023 Site Control requirements, which require site selection and acquisition of land rights far in advance of the application window.  Later release of this information will greatly impair developer land-control efforts for feasible POIs, or alternatively, lead to the need for unnecessary commitments for land at ultimately infeasible POIs.

4.4 Explore process changes to align with near-term procurement discussions:  The tax situation calls for more than general statements that the CAISO is willing to align transmission with procurement.  This issue is critical for both resource viability and cost minimization, since tax credits reduce the ultimate procurement costs to consumers.

The CAISO should initiate an intensive effort with the PTOs to identify opportunities for resources to interconnect earlier than current LGIA timelines, and to stop the continuous postponement of upgrades needed for interconnection reflected in Transmission Development Forums.  At a minimum, with respect to the latter, the CAISO should require PTOs postponing upgrades needed for resource interconnection to explore options for at least some resources to connect earlier, including on a temporary basis (until the upgrades are complete).

CAISO adoption of the proposal to accelerate FCDS designations would also greatly assist this effort.  Resources with long-lead-time DNUs must either face years of Energy Only or Interim Deliverability operation, confounding PPA contracting, or defer their CODs to match those long DNU timelines.  Earlier FCDS designations can thus lead to earlier CODs, and greater ability to take advantage of tax credits while they are available.

4.5 Responses to additional stakeholder comments:  LSA is very disappointed that the CAISO continues to defer or refuse consideration of needed modification efforts for Stand-Alone Network Upgrades and the Intra-Cluster Prioritization processes.  LSE intends to pursue needed clarifications in these and other areas through the BPM Change Management and other forums if the CAISO does not include them in this initiative.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

5.1 Managing the accumulation of stagnant projects in the queue:  LSA continues to strongly support efforts to clear the queue of non-viable projects.  In particular, LSA has supported Commercial Viability Criteria (CVC) applicability to all projects seeking COD extensions beyond 7 years time in queue, for reasons other than PTO delays.  CVC should be applicable to all projects seeking COD extensions beyond 7 years, not just those with FCDS/PCDS seeking to retain it, but also Energy Only projects.

5.2 CAISO as an Affected System process modifications:  LSA supports the CAISO’s proposal to start the Order 2023 timeline after the validation process is complete, and to tailor the study content to what is actually needed.

However, LSA does not understand the proposed Affected System study prioritization approach, where FERC directed that a project under CAISO study as an Affected System would be prioritized ahead of queue projects under study that have not received their study reports. 

CAISO rightly identifies this as a legitimate concern but then does not propose to address it.  For example, LSA does not understand how a project could request a CAISO Affected System study in the middle of the cluster-study process without disrupting any studies currently underway. 

At a minimum, the CAISO should explain how it would implement this path.

5.3 Modify the Commercial Readiness deposit due date:  This seems like a very sensible proposal, and LSA supports it.

5.4 Discontinue Pre-Application process:  Before eliminating this option, LSA requests that the CAISO provide information about how many such requests are received, and how often requests applicable to larger projects come back with smaller requested capacity to meet the eligibility requirements.

For example, if the CAISO does not plan to provide the substation-level information described above, this may be a legitimate way for developers to determine whether there any physical substation or other limitations to connections to specific POIs.  There would be less needed for the Pre-Application Process if this other information was provided earlier than Scoping Meetings, since developers could avoid the time and effort to prepare Interconnection Requests for problematic or infeasible POIs without it.

5.5 Modifications to the GIDAP Executive Dispute Committee:  LSA supports the concept of appointing a stand-in to make sure the appeals process stays on track.  However, LSA believes that there is a reason the named VPs are specified, specifically, those are the CAISO officers most likely to be familiar with the rules, practices, and precedents related to project interconnections.

Instead of having an entirely unrelated VP as a substitute, LSA believes that the first choice should be a direct report to the named VP that is familiar with the disputed issues.  If that direct report has been involved with the disputed issues, then a different VP can be named as a substitute, but still there should be an effort for that person to be a VP of a related area.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

Section 2.1 - Transparency, rigor, and integrity of the Load-Serving Entity (LSE) commercial interest point allocation process. NCPA supports CAISO’s decision “to not propose changes or suggest that any additional oversight of the LSE allocation process is necessary or appropriate.”  NCPA believes that the current process used by individual LSEs to assign commercial interest points to viable projects is sufficiently transparent and achieves the original objectives of scoring criteria based on project viability and actual LSE interest. Importantly, the current process also reflects CAISO’s lack of authority over LSE procurement decisions.

Section 2.3 - Cap on the full allocation election. NCPA appreciates CAISO’s willingness to consider proposals to address concerns regarding potentially overly constraining caps on the full allocation election option. NCPA proposes that CAISO consider two cases in which LSEs can scale the full allocation election beyond 150% of its points allocation: 1) existing resource retirements, and 2) if an LSE’s load forecast shows significant growth supporting additional points. An LSE has an absolute obligation to serve load, and CAISO should strive to develop rules as part of this interconnection process that enable LSEs to accomplish that goal in a predictable and efficient manner.

1. Generation Retirements. In addition to planning for future additional generation to support load growth and renewable policy objectives, LSEs  sometimes must replace aging generation facilities at the end of their useful life. Due to the “lumpiness” of resource retirements, the amount of capacity an LSE may need to replace the loss of an existing facility can easily exceed the current 150% LSE commercial interest points limit for the LSE in a given Cluster Application Window, particularly for small LSEs. In such cases, it is reasonable and necessary to allow an LSE to express full support for a new project seeking interconnection (whether self-built or contracted) by allowing the full allocation election cap for that LSE to increase up to the total capacity of the retiring facility (if greater than the existing 150% cap). Scaling the full allocation election cap in this manner will enable that LSE to continue to supply reliable electric service to its customers. NCPA believes this triggering condition is reasonable and manageable. Since there are a number of other formal actions that are involved in the process of retiring an existing generation facility, it should not be difficult or burdensome to verify an LSE’s need to replace retiring generation.

2. Unexpected Load Growth. Also, electrification and large load additions (with particular focus on data center integration) can result in significant unanticipated short-term increases in an LSE’s load serving requirements. Again, this is a situation in which an LSE must fulfill its obligation to provide predictable and reliable service in the face of a “lumpy” change (here demand increase, rather than generation decrease). To ensure an LSE can acquire sufficient capacity to serve unexpected increases in load growth that are due to the acute integration of large customers, the CAISO’s process should allow an LSE to express full support for a new project (seeking interconnection whether self-built or contracted) by scaling that LSE’s commercial interest points limit up to the amount of the unexpected increase in load associated with the new large customer (if greater than the existing 150% cap). This trigger is also administrable and manageable. For example, one reasonable and implementable trigger could be the LSE confirming that the amount of incremental load it will now be required to serve as a result of the addition of a new large customer(s) resulting in its forecasted load being at least five percent (5%) higher than the original load forecast being used by the CAISO for the purpose of allocating commercial interest points in the CAISO interconnection process.  NCPA is open to working with the CAISO and other stakeholders to identify a reasonable trigger that can be used to address the type of situation described herein.

While in both cases the proposed scaling of the full allocation election cap would be equally available to all LSEs, NCPA believes it would be most useful to, and most likely to be used by, the small LSEs for whom even 150% of their original points allocation may be too small. Larger LSEs would be less likely to have demonstrable needs above the 150% cap. And because the full allocation election would still limit LSEs to allocating their points to a single project, larger LSEs would also be unlikely to use it even with the proposed modification.

Section 2.5 - Clarify long lead-time resource eligibility for system need points. CAISO states that it “will identify long lead-time resources eligible for deliverability reservations for the first time in the 2025-2025 Transmission Planning Process” (emphasis added). Please confirm that CAISO is referring to 2025-2026 TPP.

Please also clarify when in the process this information will become available. NCPA looks forward to reviewing that information and providing feedback at that time. NCPA believes it is appropriate for CAISO to include the following details in the TPP process regarding long lead-time resource eligibility for system need points: resource location (busbar location), size of resource, expected commercial operations date, and identification of system constraints impacted by such long lead-time resources. This information will be critical to determine what existing resource interconnection requests may be impacted by the preemptive reservation of deliverability for long lead-time resources (especially if such long lead-time resources are at risk {of delays in commercial operation date of a year or more or of cancelation due to permitting, cost increases or any other reason. ).

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

No comment.

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

No comment.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

No comment.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

No comment.

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

No comment.

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2.1 Transparency, rigor, and integrity of the Load-Serving Entity (LSE) commercial interest point allocation process

PG&E believes that the LSE commercial interest process was fair and rigorous. PG&E conducted outreach prior to launching the points allocation process with key developers who had been active in IPE to inform the design of the first-of-a-kind process. We received a robust response from projects, including both TPD and Energy Only. One shortfall in the process was that PG&E did not have the contact information for all the projects in the queue. Despite robust communications efforts and use of our extensive listserves, some market participants complained that they found out about the process late.  PG&E believes that contact information for all queue projects should be made public.

• The ISO seeks specific feedback from the CPUC on the suggestion to include DWR as an entity eligible to participate in the LSE allocation process.

It’s unclear to PG&E how this would work since points are allocated to LSEs based on load. PG&E notes that long lead time items do have support in the allocation process through the TPD set-aside, so it is unclear that these projects will require additional points from DWR.  

2.5. Clarify long lead-time resource eligibility for system need Points

PG&E seeks clarification that the reservation process is not related only to Policy projects in the TPP, as it is possible that other processes, such as reliability upgrades or projects leaving the queue, may result in TPD becoming available for specific LLT projects. Requiring specific policy projects to be adopted in order to reserve TPD for LLT projects would limit flexibility and could result in additional transmission projects needed, given the relative ease of developing 4-hour duration batteries quickly.

2.6. Monitor trends in Energy Only interconnection requests for alignment with resource portfolios

Like Clearway and LSA, PG&E supports avenues to allow projects that are Energy Only to be able to receive TPD, including CalCCA’s proposal to allow Energy Only projects to re-enter the queue for TPD. While IPE 2023 made needed changes in reforming the queue, there are issues that the MOU process has not been nimble enough to address- namely the rapid rise in data center related load forecasts and associated needs for deliverable generation. Theoretically, LSE preferences as expressed through IPE should select deliverable generation. However, these signals have not had time to filter through to developers. Thus, the current shortfall is not simply the amount of MW in the queue, but the type of MW (generation vs storage) and - as stated by Sempra Infrastructure - when those resources can get online.

In Opening Comments on CPUC Staff’s Reliable and Clean Power Procurement Program, PG&E presented an RA Slice-of-Day (SOD) based stack analysis for 2030. PG&E’s analysis indicates there is effectively insufficient energy storage charging capacity to meet the SOD’s energy storage charging sufficiency requirement for September 2030, meaning, additional deliverable capacity is needed from generating resources or co-located energy storage resources shown to have sufficient charging capacity (e.g., sufficiently sized co-located resources). To address the energy deficiency found in PG&E’s analysis, PG&E has proposed either a CPUC reliability assessment or an interim procurement order for zero-carbon generating resources. LSEs in aggregate would have to procure roughly 10.2 GW - 12 GW of deliverable wind and/or solar to ensure September 2030 SOD RA requirements are met. While co-located resources are eligible in PG&E’s proposal, co-located resources could be a more expensive solution to the deliverable energy short because the storage component is not necessary to address the shortfall found in PG&E’s analysis.[1]

However, PG&E does not see any stand-alone solar generation projects seeking FCDS in the C13-C15 queue, and wind projects in the queue are unlikely to be available by 2030, even if FCDS. Further, it appears that only 29% of the C15 projects seeking FCDS have any renewable generation associated with them, while 33% of the total C15 projects are Energy Only, so, if these projects can get TPD, they could cost-effectively serve the need for deliverable energy generating resources under the SOD Resource Adequacy analysis presented by PG&E in the IRP Proceeding.

PG&E shares the CAISO’s concern for projects lingering in the queue but suggests that this should be reviewed through time in queue and milestone requirements. PG&E does not believe that allowing EO generation projects to get TPD is gaming the system, especially given the amount of time needed for signals to filter through the MOU process as compared to the expected timing of data center load growth.

[1] https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M573/K391/573391964.PDF

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

• CalCCA proposal to allow EO projects to re-enter the queue and get studied for TPD.

PG&E supports CalCCA’s proposal, though the merits of needing to go through the TPD allocation process versus being eligible to receive TPD in the next allocation cycle should be discussed. The energy need landscape has dramatically shifted in the last year or so, resulting in PG&E’s proposal for mandated procurement of deliverable generation in the near future, as described above.

3.1 Clearway and LSA suggested allowing projects that fail to get deliverability to switch to Energy Only rather than exit the queue entirely.

Respectfully, and as stated in many previous comments, PG&E does not agree with the CAISO about the “3 strikes” policy requiring projects to withdraw from the queue. PG&E supports allowing these projects to switch to EO status and have the chance to get TPD again when COD, if they continue meeting development milestones. The stakeholder meeting highlighted that these projects will need to proceed with their GIAs and deposits per FERC Order 2023, putting the developers in the absurd situation of needing to withdraw a project already under construction.

PG&E reoffers our previous recommendations from December 3, 2024. These projects should be given the option to continue as Energy Only projects if they meet all financial commitments to the Participating Transmission Owners (PTO). PG&E proposes that projects that enter the queue seeking to be studied for deliverability be allowed to seek a TPD allocation after they come online in either a group 1 or 2 allocation.

PG&E offers the following in response to the CAISOs reasons for supporting the proposal.

• PG&E’s proposal would only apply to projects that are not stalled or lingering.
  • PG&E proposes FCDS-seeking projects be eligible to continue as EO if the IC has posted 100% of their cost responsibility (to ensure only projects which can be commercially viable as EO move forward) and are current in their obligations.
  • Indications that projects aren’t stalled, or lingering, include:
    • Projects that are seeking TPD have had substantial investment already.
    • These projects will have met FERC Order 2023 requirements to enter the cluster and will have received sufficient points to be studied.
    • By the time the TPD allocations occur, projects will have signed their LGIAs per FERC Order 2023 and may have advanced permitting to get more points for the TPD allocation process.
  • These projects will still be subject to the seven-year time in queue restrictions, much of which will already be over through the three TPD cycles.

• PG&E does not believe our proposal interferes with the commercial process or points allocation process developed in IPE track 2. The proposal only applies to projects that sought TPD, so may have received points.
• The CAISO has suggested that if a project does not get a PPA to get TPD after three cycles, it may not be a commercially viable project. However, while a PPA moves a project into the first category, it does not guarantee that TPD is available, meaning that the project could be commercially viable. Additionally, PG&E has found that when projects have a COD that is far off, even if they have deliverability, developers are not able to easily price the product and seek more complicated contractual terms, like indexing. Both these examples support that highly viable projects could be positioned to get EO PPAs.  By the time the 3 TPD cycles have passed, the COD may be closer, increasing viability.  These projects could be more viable than comparable EO projects just starting off their development process in a cluster that is 3-4 years newer than the cluster of the original projects. 
• Regarding reservation of TPD for projects that seek TPD allocation, this subset of projects did originally seek TPD.
• While PG&E understands that past EO projects have not come online, IPE track 2 and FERC Order 2023 have changed the processes to come online, and past data may not be reflective of future results. Projects that continue to meet development milestones are not “lingering” if they are current on all GIA obligations.

PG&E’s concern is that forcing withdrawal may engender system inefficiencies, that ultimately cost customers. While, in many cases, PG&E hopes that three years will provide ample time to price the project and obtain a PPA, there are developers who may want to develop their projects at their own risk and are willing to move forward. PG&E is concerned that, given recently updated load forecasts within the CEC’s 2023 Integrated Energy Policy Report (IEPR),[2] forcing projects to withdraw to defer to later queue projects will delay the ability to meet load. Rather than force withdrawal, PG&E would like to see guardrails to prevent lingering and allow projects that are not lingering to proceed.

[2] See details on the CEC’s website at the following link: 2023 Integrated Energy Policy Report.

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

5.1 Queue Management

PG&E respectfully requests that CAISO provide a comprehensive and data-supported clarification regarding the rationale for not incorporating the Time in Queue limits—approved by the CAISO Board under the IPE Track 2 proposal—into the tariff. Stakeholders have invested substantial time and effort in developing this proposal, which aims to address the challenges posed by projects that remain in the interconnection queue for extended periods. A detailed response would be greatly appreciated.

In the absence of enforceable Time in Queue limits, speculative projects—particularly those submitted prior to the implementation of FERC Order 2023 requirements for site control and financial withdrawal penalties—lack sufficient incentive to advance toward execution or to make their third financial postings. These lingering projects may be associated with Network Upgrades that are prerequisites for later-queued projects. Additionally, they may occupy critical bay positions in substations with limited expansion capacity, thereby forcing subsequent projects to fund costly bus conversions and experience delays in achieving milestone dates. This dynamic directly impedes the progress of projects that are otherwise ready to proceed. Given the dual challenges of projects lingering in the queue with the need to allow projects that will develop, even as energy only, to move forward, CAISO implementation of Time in Queue limits is critical.

Despite having limited prospects for reaching commercial operation, many projects have undergone validation, submitted deposits, and executed interconnection agreements. The sheer volume of projects in CAISO’s interconnection queue intensifies existing supply chain challenges for essential components such as circuit breakers, switches, and transformers. As these projects linger, Participating Transmission Owners (PTOs) initiate procurement activities, placing additional strain on the supply chain. Frequently, these orders are subsequently canceled, resulting in wasted resources, disrupted procurement strategies, and capital tied up in surplus inventory. This inefficiency delays the deployment of viable projects and hinders progress toward a more resilient and sustainable energy grid.

Another critical issue associated with lingering pre C15 projects is the discrepancy in base case assumptions between Cluster Studies and Transmission Planning Process (TPP) studies. This discrepancy can result in significant differences—on the order of tens of gigawatts—in assumed generation levels, particularly in regions with high concentrations of queued generation. Consequently, short circuit duty margins may vary substantially between the two study base cases. When major TPP projects are proposed, the TPP study may not reflect the same level of system overstress observed in the Cluster Study, leading to the need for development of extensive mitigation measures within the compressed timeline of the Cluster Study. This creates uncertainty in cost allocation between TPP and Cluster projects, affecting project milestones, cost responsibility, and overall viability—ultimately obstructing the advancement of first-ready projects.

To address these concerns, PG&E proposes that stakeholders discuss whether all pre-QC15 projects be required to submit a deposit calculated based on their total Network Upgrade cost. This deposit would be applied toward the project's Network Upgrade expenses upon commencement of construction. The deposit amount would increase annually by a fixed percentage unless construction begins, with exceptions made for permitting or utility-related delays to avoid penalizing Interconnection Customers (ICs) unfairly. Projects that do not intend to proceed would thus have a financial incentive to withdraw from the queue. Upon withdrawal, the deposit could be used to fund any outstanding Network Upgrades for which the project was responsible. If the project does not trigger any Network Upgrades and there are available bay positions at the interconnection substation, the deposit may be refunded to the customer. PG&E acknowledges that this proposal would require significant administrative effort; however, the scale and complexity of the issues caused by lingering projects in the queue warrant decisive action to mitigate their impact.

5.2  Affected System

PG&E concurs with SCE’s comments regarding the tariff language stipulating that an Affected System Queue position should be considered of higher priority than any cluster that has not yet received its Cluster Study Report. Given the compressed timeline of 150 calendar days for completing the Cluster Study, Participating Transmission Owners (PTOs) require validated models for the Affected System Project, as well as models for any associated mitigation measures or upgrades that the Affected System Project may necessitate on the PTO’s system. These models must be available prior to the commencement of base case development for the Cluster Study. The absence of such data at the outset of the study could result in delays.

Furthermore, if the utility where the Affected System Project is interconnecting does not fall under CAISO jurisdiction, it remains uncertain how coordination can be ensured to provide the necessary data in advance of base case development. This uncertainty is compounded by the fact that non-CAISO jurisdiction utilities may operate under differing timelines.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

PG&E requests that PTOs be included in the scoring process to provide insights on how the projects could be interconnected so that CAISO’s TPD calculation for the 150% limit is not based solely on customer’s POI request. As we saw in QC15 cycle, CAISO received the largest number of 500 kV applications to date, and it is simply not feasible or economical to build that many new 500 kV stations.

PG&E would also request CAISO to consider PTO input before publishing an updated constraint mapping sheet to ensure line names are updated. In QC15, there were several instances where the POI request from the IC was a transmission line which does not exist anymore. This would help smooth the IR validation process.

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

REV Renewables (REV) appreciates CAISO opening this initiative to continue discussing IPE Track 2 issues. REV has no comments at this time but looks forward to reviewing proposals that may emerge in this process.

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

REV is interested in continuing discussions around operational Energy Only projects to receive deliverability, including options to support storage charging sufficiency.

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

 REV supports this designation.

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

CAISO’s first intra-cluster prioritization process provided meaningful progress for several projects in SCE and SDG&E territories. However, we strongly believe that the process did not work that well for PG&E territory. This appears to be primarily due to CAISO’s exclusion of generation interconnection-driven Precursor Network Upgrades (PNUs) from the prioritization framework. Based on our understanding, this exclusion impacted a lot of Bay area projects, despite the region being projected as resource-deficient in 2026 and beyond, as highlighted in the 2026 Local Capacity Requirements (LCR) study. We recognize that expanding the scope of the process from TPP driven PNUs to interconnection driven PNUs will broaden the scope from intra-cluster to inter-cluster prioritization introduces resulting in additional complexity. However, we believe this complexity can and should be managed on a case-by-case basis, with flexibility to adapt as needed. This approach is especially important for ensuring that projects in resource-deficient areas have viable and timely pathways to come online.

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

SDG&E appreciates and supports CAISO’s effort to undergo a stakeholder process and receive comments and feedback for the interconnection procedures, following the implementation of IPE 2023. During the August 11, 2025 stakeholder meeting, CAISO described their approach to their proposed changes, which was helpful to gain a better understanding of the scope for this effort.

SDG&E agrees that the commercial interest (CI) point allocation process established in IPE 2023 is rigorous and equitable and does not need any immediate changes outside what has been contemplated regarding the full allocation election. The point allocation process appears to be working well, and SDG&E agrees with CAISO’s assessment that no additional oversight is needed for the load serving entities (LSE) allocation process. SDG&E does not have any additional proposals for the full allocation election outside what was included in earlier comments.

SDG&E does not support the inclusion of the California Department of Water Resources (CDWR) as an entity eligible to participate in the CI point allocation process. The current approach to the commercial interest point allocation appears to successfully balance diverse needs and positions to determine which projects are best positioned to advance to the study process. The IPE 2023 proposal categorically included consideration of long-lead time resources in the scoring process to ensure alignment for these projects to enter the queue. This includes resources that have been identified for procurement through the CDWR. Given these existing rules, SDG&E believes there are sufficient opportunities for long-lead time projects to earn points through project viability and system need points. Additional points allocation to CDWR seems duplicative given this accommodation for CPE resources. Further, CDWR is not currently an LSE, nor does it fall within the non-LSE offtaker category as contemplated in IPE 2023. As the allocation of points could not be based on load share, inclusion of CDWR in this category would require a new allocation mechanism for the commercial interest points segment.

SDG&E supports CAISO’s proposal to incorporate WDAT projects seeking deliverability into the intake scoring and the 150% study limit processes. This step will ensure that deliverability is not overprescribed, and that the portfolios remain reliable for planning processes going forward

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

None

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

None

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

SDG&E supports CAISO’s Commercial Readiness Deposit proposal and appreciates CAISO’s innovative methods to address previously stated concerns around this issue.

Some GIA negotiations can require significantly more time and resources than others. This can reduce the ability of PTOs to devote equal attention to other customers who are ready to move forward. SDG&E proposes that PTOs can accrue and invoice hours for payment by ICs after a reasonable time threshold beyond the contract negotiation period (perhaps 90 or 120 days), specifically if delays are driven by the IC.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

None

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

1. Upgrade Reassignment Following Project Withdrawals:

Currently, the tariff does not appear to include provisions for the reassignment of Shared Network Upgrades when a project withdraws from the queue. For example, if a project in Cluster N is assigned a SANU that is also needed by a project in Cluster N+1 (assigned as a CANU/PNU), and the Cluster N project subsequently withdraws, there is no clear guidance on whether the SANU—and its associated cost responsibility and construction timeline—should automatically transfer to the dependent project in Cluster N+1

SDG&E recommends that the tariff be updated to include language that:

a. Establishes a mechanism for automatic reassignment of upgrades to dependent projects in subsequent clusters upon withdrawal of the original project.

b. Clarifies how cost responsibility and construction timelines will be adjusted in such cases.

c. Ensures transparency and fairness in upgrade allocation to maintain queue efficiency and project viability.

2. Accountability for Prolonged Queue Participation Without Progress:

SDG&E appreciates CAISO’s efforts to improve queue efficiency and reduce project stagnation. However, there still remains the ability for projects to stay in the queue for years while negotiating a LGIA, with no clear intent to execute the agreement. This highlights a gap in the current tariff language regarding accountability for projects that delay progress prior to entering a GIA. We suggest incorporating additional provisions that:

a. Introduce accountability measures for projects that remain in the queue without demonstrating meaningful progress toward executing a GIA.

b. Consider language similar to breach provisions that would apply to projects exhibiting prolonged inactivity or lack of engagement.

SDG&E notes that CAISO’s original board approved queue management proposals from IPE Track 2 around Time-in-Queue and Commercial Viability Criteria demonstration

accomplished all of the above. CAISO should consider reintroducing those provisions fully, or in a partial manner that will meaningfully address prolonged queue participation without progress

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2.1 – Load-Serving Entity (“LSE”) Commercial Interest Points Allocation Process:  The Six Cities agree with the CAISO’s conclusion that no changes to the LSE allocation process for commercial interest points are needed at this time.  Local regulatory authorities for LSEs are in the best position to evaluate the transparency, rigor, and integrity of LSE procurement practices, including the allocation criteria for commercial interest points. 

2.3 – Cap on the Full Allocation Election:  The Six Cities opposed the implementation of a cap on the full allocation election option in Track 2 of the IPE 2023 initiative, which was a policy element that emerged at a late stage of the Track 2 process.  The cap on an LSE’s full allocation election has the potential to disadvantage small LSEs, which are restricted from exercising the full allocation election for projects with interconnection service capacity requirements that may exceed, even by a limited amount, 150% of the LSE’s points.  Smaller LSEs in particular may have procurement needs that are intermittent or “lumpy,” and there can be sound reasons for LSEs to engage in multi-year procurement of a resource that represents a relatively large share of the LSE’s load, rather than procuring small amounts of capacity each year (or in each interconnection study cycle).  Additionally, given the size of resources that typically enter the queue, there may be limited or no resources of a size that is proportional to a small LSE’s procurement needs, which could essentially nullify the benefit of the full allocation election.

To address, at least in part, the concerns with these procurement limitations, the Six Cities request that the CAISO consider establishing two exceptions to the cap: first, if the exercise of the full allocation election to a project that is larger than the 150% threshold is to replace a project that is already included in the LSE’s resource portfolio; or, second, if the use of the full allocation election at a level that is above the 150% threshold is needed to address a known and measurable change in the LSE’s load forecast that is not reflected in the LSE’s allotment of points for a particular cycle.  The CAISO could permit the use of these exceptions subject to monitoring and potential changes in future IPE stakeholder initiative cycles if misuse of the full allocation election option is observed. 

2.7 – Incorporation of Distribution System Interconnection Projects in the Intake Scoring and 150% Study Limit Processes:  The CAISO’s proposal to require distribution-level interconnection projects to participate in a cluster deliverability study and in the intake scoring in particular requires additional examples and discussion.  As an initial matter, the Six Cities do not support CAISO tariff-based restrictions on the ability of municipal utilities to develop and use for resource adequacy (“RA”) purposes projects within their own municipal distribution systems.  Based on the conceptual information in the CAISO’s Straw Proposal, the Six Cities are concerned that the intake scoring requirements (particularly when combined with the full allocation election cap) will prevent municipal utilities from developing projects within their distribution systems that can be used to meet their own RA needs. 

To enable parties to more fully evaluate this proposal, it would be helpful to receive in the next version of the proposal in this initiative a comparison of how the CAISO envisions its proposed process, particularly for deliverability allocation to distribution connected resources, would differ from the process that is used today.  In terms of the application of the scoring criteria, it would be helpful to understand how the CAISO believes these criteria may have affected the allocation of points and the projects that advanced to the interconnection study process. 

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

3.1 – Allowing Operational Energy Only Projects to Seek Deliverability:  Specifically with respect to section 3.1, relating to the development of a potential pathway for projects in Cluster 15 and subsequent clusters that come online as energy only projects to later seek a deliverability allocation, the Six Cities concur in CalCCA’s observation in its July 16^th comments in this initiative that operational projects are likely “more viable than earlier-stage projects” and could “offer more affordable and timely pathways for additional deliverable supply.”  At the same time, the Six Cities acknowledge the CAISO’s concerns regarding expectations of need for energy only projects, its desire to manage the amount of energy only capacity in the queue, and the practical timing considerations of when a Cluster 15 energy only project would likely be online and in a position to seek a deliverability allocation under a new power purchase agreement.  In other words, with respect to this latter point, the Six Cities agree with CalCCA that more capacity is needed, but it’s not clear that policy changes regarding the ability of energy only projects in Cluster 15 to seek deliverability allocations once online could be implemented in time to meaningfully address capacity needs that are immediate and near term. 

If the suggested approach by CalCCA is adopted—and the Six Cities reiterate that they do not oppose further discussion of this proposal—the Six Cities agree that opportunities for energy only projects to obtain deliverability should be narrowly tailored and limited in a way that this avenue does not become an avenue to circumvent aspects of the interconnection and deliverability study processes. 

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

The Six Cities have no comments on the topics addressed in section 4 of the Straw Proposal at this time.  

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

5.1 – Managing the Accumulation of Projects in the Queue:  As discussed in the Straw Proposal and at the stakeholder meeting, the CAISO developed revised policies as part of Track 2 of the IPE 2023 initiative that were intended to address accumulation of projects in the interconnection queue.  Although the CAISO has advised that it has since determined these proposals would not impact a meaningful number of projects and could be burdensome, the Six Cities request a more complete discussion of how the CAISO reached this conclusion, which elements of the policy were deemed to create administrative challenges, and whether there are elements of this policy that could be implemented or adapted to address these concerns.  Given the level of effort in the prior stakeholder process to develop rules around this topic, at a minimum, the CAISO should fully assess with stakeholders the basis for its decision to abandon these requirements. 

5. Provide your organization’s comments on section 6: WEM Governing Body Role

The Six Cities agree that the CAISO’s interconnection and deliverability allocation rules in its tariff are subject to the oversight and approval of the CAISO Board of Governors. 

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

The Six Cities have no additional comments at this time. 

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2.6 Monitor trends in Energy Only interconnection requests for alignment with resource portfolios

Because Energy Only (EO) resources must be evaluated for their contributions to short circuit duty (SCD) and potential reliability network upgrades, SCE requests the CAISO to include the development of a cap on EO projects as part of its IPE 5.0 initiative.  SCE does not believe that simply monitoring trends in EO interconnection requests is sufficient. Although EO projects do not impact the potential need for deliverability network upgrades, these EO projects directly contribute to the need for reliability network upgrades, such as short circuit duty upgrades to accommodate their short circuit contribution and bus extensions to accommodate their physical interconnection. Many of the SCE long-lead time upgrades from Queue Cluster 14 were driven by short circuit duty. An uncapped number of EO projects could continue to clog the interconnection queue and unnecessarily impede projects that align with the state’s generation portfolio by causing them to be assigned excessive reliability network upgrades and consuming study/interconnection request management resources as well. Incorporating short circuit duty headroom into transmission capacity assumptions, such as capping new projects, including EO  projects, once limits are nearly reached, would help manage reliability risks and avoid triggering disproportionate upgrades.  One such option would be to cap these projects in the queue at 150% of the total proposed EO projects in the CPUC portfolio.

 2.7 Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes  

SCE supports CAISO’s proposal to incorporate distribution system interconnection projects (e.g., for SCE, projects interconnecting under its Wholesale Distribution Access Tariff or WDAT) into the intake scoring and 150% study limit processes.  Furthermore, SCE supports the CAISO’s stated vision that “…Wholesale Distribution Access Tariff (WDAT) projects and similar distributed energy resources compete for deliverability under requirements on par with transmission-connected resources.[1]” SCE agrees with the CAISO that it is the CAISO’s responsibility to perform the intake scoring and the 150% study limit process for distribution interconnection projects seeking deliverability, similar to projects interconnecting directly to the CAISO grid.   In addition to intake scoring and the 150% study limit process, the CAISO’s draft final proposal should address how distribution system interconnection projects will participate in the “tiebreaker” auction process for cluster study criteria and the Merchant Option, including identifying any new agreements between the CAISO and the distribution system interconnection project owner that may be necessary.   

SCE looks forward to collaborating with the CAISO through this IPE 5.0 policy initiative to establish the details of the coordination efforts that will be required between the CAISO and UDCs regarding the tasks, responsible party, and hand-offs in this new interconnection requests intake process. 

The IPE 5.0 should also include the applicability of other IPE elements which implicate the CAISO tariff and processes to WDATs (e.g., application of shared network upgrade requirements in GIDAP Section 11.3.2.6).  In particular, the CAISO should require a WDAT that shares a network upgrade with a TO Tariff project to execute a Generator Interconnection Agreement (GIA) or interim Letter Agreement for its pro rata share of the proposed shared upgrade and at the time the transmission-interconnected project executes its GIA.  By requiring the WDAT to also execute supporting agreements, all costs will be accounted for and have been addressed. Currently, the UDC has no tariff authority to require such treatment when the transmission-interconnected project executes its Interconnection Agreement.

NOTE: Please see SCE’s attached proposed revisions to GIDAP Section 11.3.2.6 regarding inclusion of WDATs. SCE is open to working with CAISO and stakeholders on the appropriate wording and revisions to Section 11.3.2.6.

[1] IPE 5.0 Straw Proposal, p. 12.

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

SCE has no comments on this topic currently.

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

 4.1 Deliverability reservations for projects waiting for long lead-time delivery network upgrades

 SCE agrees that additional reforms are currently not needed. SCE does not support reservations of TPD.

4.2. Adjust required generator interconnection agreement (GIA) execution to be after all deliverability allocations are complete

SCE supports the CAISO’s proposal to retain the existing FERC Order No. 2023 timeline for GIA execution.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

5.1 Managing the accumulation of stagnant projects in the queue

CAISO’s proposal includes this sentence: “For instance, the ISO is considering a rule prohibiting COD extensions beyond three years or establishing stricter time-in-queue and viability requirements triggered when an interconnection customer requests a milestone extension.”

SCE is in support of the CAISO considering such a rule but requests additional information and clarification before commenting further. SCE requests the CAISO clarify whether there are stagnant pre-Cluster 15 projects, given the existing CAISO requirements for those projects to execute an interconnection agreement or be deemed withdrawn.

5.2 ISO as an Affected System process modifications

SCE appreciates the CAISO responding to SCE’s concerns regarding the process steps of Affected Systems (A/S) studies and supports the CAISO’s proposal. SCE agrees that the proposed changes will realign the process steps, resulting in a more effective and workable process. To further improve the efficiency of the A/S studies, SCE recommends the CAISO add language to Appendix KK, Section 14.5.2, that would instruct the Customer to submit an Initial Study deposit of $1,500. 

Furthermore, SCE shares the CAISO’s concern about the Affected System Queue Position described in Section 14.5.3. To clarify, SCE believes that the Affected System Queue Position should be assigned based upon the Affected System Interconnection Customer’s Interconnection Request(s) being deemed complete and valid, and the execution of the Affected System Study Agreement. CAISO and the Affected Participating TO will study the Affected System Interconnection Customer(s) in coordination with the Cluster Study Process to ensure that the study windows do not conflict with the earlier queued Cluster.  

5. Provide your organization’s comments on section 6: WEM Governing Body Role

SCE has no comment on this topic currently.

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.

In addition to the items the CAISO discusses, SCE also raises concerns regarding the use of the term “Construction Activities” in section 11.3.2.6. The outcome of IPE 2023 Track 2 discusses setting requirements on “when activity has begun on the network upgrade and interconnection facilities.” However, the subsequent final tariff references a requirement using the specific term of starting “Construction Activities” within 30 days. This CAISO term is defined as occurring “after receipt of all appropriate governmental approvals needed.” Licensing and permitting activities covered as “Pre-Construction Activities” can take years to secure and it is not reasonable that such activities can be completed within the 30-day timeframe. To make Section 11.3.2.6 practical and feasible, the CAISO tariff needs to be revised to instead require the start of “Pre-Construction Activities” within 30 days. Alternatively, if the CAISO prefers to continue with the use of “Construction Activities”, then the CAISO must either limit the type of “Construction Activities” that will be subject to the 30-day window or remove the 30-day requirement from the tariff.  As written, the tariff is unworkable, and it must be modified.  

1. Please provide your organization’s comments on section 2: Commitments from 2023 IPE Track 2.

Please provide each topic’s specific section number used in the Straw Proposal to identify the topic you are commenting on for each of these questions.

2.7. Incorporation of distribution system interconnection projects into the intake scoring and the 150% study limit processes: 

This proposal should not be advanced at this time. It is not entirely clear what problem this proposal is trying to solve. WDAT projects have different attributes than LGIA interconnecitons, one of the primary advantages being much faster timlines for development and interconnection studies and upgrades to the distribution system. Indeed, some projects can reach COD within 12-18 months from the initial Interconnection Application. By requiring WDAT projects to "compete for deliverability under requirements on par with transmission-connected resources" you are requiring compeittion on an uneven playing field, as the CAISO Cluster Study will take the most amount of time and eliminate the main advantage of connecting Distributed Energy Resources to the grid, especially in areas where there are near term grid constraints. 

There is an existing - Deliverability for Distributed Generation process, which seems to be in need of reform, and the IPE process should start with that effort rather than this proposal. At minimum, the DGD process should be evaluated and modified alongside any potential changes outlined in the straw proposal. 

It is also unclear how Network Upgrades may be treated under this new requirement. More consideration is needed in understanding how WDAT projects are currently allocated Network Upgrades, and what elements of those Network Upgrades are reimubrsable (or not) for WDAT projects. Important distinctions in the SGIA vs. LGIA agreements should be well understood before this proposal is advanced. 

In many situations, WDAT projects pass the Transmission Electric Independence Test (EIT Test Screen Q & Screen R), meaning they do not impact the transmisison system. These project would service local/regional load and the notion they would need to go through a CAISO cluster study when they are already determined to be independendent from the transmission system. Perhaps this proposal would make a distinction between those projects that fail the Transmission EIT Test (and thus need to be studied by CAISO), vs. projects that do not have a transmission connection and are deliverable to local load. 

Another important topic is how points will be evaluated and awarded for WDAT projects. Will LSEs need to give commercial interest points to WDATs, or will the WDAT projects automatically receive the full amount of points in that category? Any requirement to have LSEs award points to WDATs projects does not seem efficient or practical. There would need to be a whole effort to create a fair and transparent scoring methodology for WDAT projects, which does not seem needed, especially given the opportunity to reform the DGD process. 

Lastly, there are multiple conversations taking place at the CPUC and CEC regarding Front of the Meter solar + BESS projects being treated as Load Modifiers. It will be important to understand how this policy and regualtory process unfolds before making this proposed change to WDAT projects. A recent Power Flow Study indicates that at least 6GW of FTM DG projects provide significant value to the CAISO system, and can come online quickly and avoid the need and costs for new Transmission. The opportunity to have community scale, dispatchable DER resources provide needed Deliverability without the need for Transmission seems like a meaningful opportunity for California and CAISO ratepayers, and it is unclear how this proposal will support that endeavor, and many potential reasons why implementing a change like this would in fact eliminate these resources from participating, given the unclear and uncertain outcome that this unequal 'competition' might create. 

the-value-of-community-solar-and-storage-in-caiso.pdf

~Ben Peters

US Solar

2. Provide your organization’s comments on section 3: Commitments from 2023 IPE Track 3.

3. Provide your organization’s comments on section 4: Additional stakeholder suggestions.

4. Provide your organization’s comments on section 5: Additional ISO proposals: Affected system, commercial readiness, pre-application process, dispute committee, queue management.

5. Provide your organization’s comments on section 6: WEM Governing Body Role

6. Please provide any additional comments on the straw proposal or Aug 11 workshop discussion.